FERC Filings

Motion of EPSA for Leave to Intervene Out of Time and Comment on PJM Northern Illinois Control Area Mitigation

Conclusion

EPSA has significant concerns about the PJM NICA capacity market mitigation proposal overall, and the MMUs use of an untested analytical framework for assessing market power specifically. The Commission must reject the PJM proposal due to an insufficient showing that there is excessive market power in the NICA capacity market and because additional mitigation measures are not necessary within the PJM market structure.

May 26, 2004 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, DC 20005
(202) 628-8200

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., May 26, 2004.




________________________
Julie Simon

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