FERC Filings
Motion for Clarification of the Electric Power Supply Association re: Price Discovery in Natural Gas and Electric Markets
The Commission Should Clarify The Requirement To "Verify" Transactions
Finally, EPSA asks that the Commission clarify the term verify of section 2 in paragraph 34. In this section, the “personnel responsible for reporting trade data should also verify the accuracy and completeness of the data before submitting it.” In order to qualify for safe harbor protection, it is unclear what standard of verification is required here in the Policy Statement. For example, it is possible, though probably not reasonable, to require the data provider to reconfirm each and every transaction before it is reported. That level of verification is clearly a much more expensive and time-consuming process than more general spot checking and/or investigation of outlying data. It would be very helpful to data providers if the Commission’s expectations on this point were clarified, so that the reporting entities could comply with these expectations.
EPSA shares the Commission’s interest in improving the reliability of and confidence in price indices and appreciates the Commission’s efforts to develop a safe harbor policy protection to encourage voluntary, good faith reporting. The Policy Statement is an excellent step forward in that direction. EPSA respectfully submits that providing greater clarification on the issues identified herein should help further the goal of promoting increased voluntary reporting of transaction information by market participants.
September 10, 2003
Respectfully submitted,
Julie Simon, Vice President 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., September 10, 2003.
________________________
Julie Simon