FERC Filings
Comments of EPSA re: Amendments to Blanket Sales Certificates
Introduction
Amendments to Blanket Sales Certificates
Docket No. RM03-10-000
Pursuant to the Commission’s June 26, 2003, Notice of Proposed Rulemaking (NOPR) on Amendments to Blanket Sales Certificates for Unbundled Gas Sales Services in the above-captioned proceeding, the Electric Power Supply Association (EPSA ) hereby files comments on the Commission’s proposal.
Growing out of its investigation of western markets and as part of its efforts to address price index issues, the Commission issued this proposed rulemaking to adopt a code of conduct for unbundled pipeline sales and holders of blanket marketing certificates (Code of Conduct NOPR), as well as a related order seeking comment on the adoption of market behavior rules for holders of electric market-based tariffs and authorizations (Electric Market Behavior Rules Order). During its western investigation the Commission found that electric power and natural gas markets are significantly interrelated. EPSA members are well aware of this relationship as both users of gas and pipeline shippers, as well as producers and marketers of electricity.
The Commission’s proposed behavioral rules for both the electric and gas industries are very similar, but should be even more consistent with each other. EPSA has been very active in the relevant electric dockets and herein files comments in the instant proceeding in order to echo our concerns with the Electric Market Behavior Rules Order, as these two rules are inevitably linked and must be consistent. In addition, as large gas consumers, EPSA is concerned about certain policy issues raised exclusively by this NOPR—specifically the adoption of rules that would be applicable to only certain wholesale sellers of natural gas, thereby bifurcating the national market for natural gas.