FERC Filings

Comments of EPSA re: Amendments to Blanket Sales Certificates

Overview

EPSA supports the development of standards and rules that will facilitate robust and seamless competitive national markets for both natural gas and power. In comments filed on the proposed revisions to electric market-based rate tariffs and authorizations, EPSA and other competitive suppliers have prepared a red-lined version of the behavioral rules to capture important clarifications and considerations to be considered by the Commission. Such rules must be clear to all market participants and include an adequate level of specificity so that all participants are “on notice” as to acceptable and unacceptable market behaviors. EPSA includes red-lined and clean attachments herein to inform this proceeding as well (see Attachments A and B).

In this case, however, EPSA is concerned that the proposed rules will apply only to a portion of the market and thus bifurcate national natural gas markets. EPSA has long advocated workably efficient, competitive and broad energy markets, be they natural gas or electricity. The Commission and Congress, through a long series of legislative and regulatory pronouncements, have largely achieved this goal in the natural gas industry. Hence, EPSA is particularly concerned that the Commission would now propose to put in place behavioral rules that the Commission readily concedes would only apply to a portion of the market. Due to this “partial application,” EPSA does not believe that the Commission should adopt the proposed rules for the natural gas industry. However, if the Commission believes such rules are necessary, then EPSA urges that the suggestions made for the Electric Market Behavior Rules be adopted for the blanket sales proceeding as well.

• View Previous Section
• View Next Section
• Back to Issue Menu