FERC Filings

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

Conclusion

EPSA continues to express concern about the predominant focus on generation market power when, in fact, transmission market power, barriers to entry—such as buyer market power— and affiliate abuse often create more formidable obstacles to robust competition in today’s wholesale markets. Vigorously applying each prong of the test is essential to detecting and mitigating market power. A comprehensive review of the Commission's market-based rate program will shed valuable light on the full range of mitigation methods and market power tests, and provide a critical perspective on the current state of market development in various regions of the country. Hence, EPSA urges the Commission to expedite the issuance of a comprehensive rule addressing and codifying the full range of market power considerations to be assessed and reviewed by the Commission when granting electric market-based rate authority.

Respectfully Submitted,

Nancy Bagot, Vice President of Regulatory Policy
Electric Power Supply Association
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
(202) 628-8200



March 14, 2005

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