FERC Filings

BRIEF OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON COMMISSION STAFF’S INTERPRETATION OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR’S AND CALIFORNIA POWER EXCHANGE'S MARKET MONITORING AND INFORMATION PROTOCOL

CONCLUSION

EPSA urges the Commission to proceed cautiously in this proceeding. The vague protocols in these tariffs were not intended to proscribe certain market behavior. By using these protocols as the basis for show cause orders, the Commission would be penalizing market participants without adequate definition of the rules. The Commission has not let ISOs do this in the past and it should hesitate to allow it here.

April 11, 2003

Respectfully submitted,


____________________________
Julie Simon, Vice President of Policy
Nancy Bagot, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, NW 11th Floor
Washington, D.C. 20005
Tel:
202-628-8200
Fax:
202-628-8260

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., April 11, 2003.

__________________
Julie Simon

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