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FERC Filings

EPSA Comments on FERC's Post-Technical Conference on Market-Base Rates for Public Utilities

Preface

The Electric Power Supply Association (EPSA) appreciates the opportunity to submit comments in response to the Federal Energy Regulatory Commission’s (FERC or Commission) Dec. 9, 2004 “Notice Inviting Comments” on issues discussed during the Commission’s Dec. 7, 2004 technical conference in the above-captioned rulemaking. EPSA vigorously supports the Commission’s efforts in this rulemaking proceeding to clarify and codify a comprehensive test for granting market-based rate authority to public utilities. Particularly, EPSA stresses how critically important it is for the Commission to develop strong criteria and attach equal weight to each of the four analytical prongs when making market-based rate authority determinations.