FERC Filings

EPSA's Post-Technical Conference Comments on Market-Based 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) Feb. 11, 2005 “Notice Inviting Comments” on issues discussed during the Commission’s two-day technical conference, held January 27 and 28, 2005, in the above-captioned rulemaking. EPSA whole-heartedly 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. As EPSA has stressed in previously filed comments in this proceeding, it is of vital importance that the Commission develop strong criteria for each of the four prongs of the market power test, and attach equal weight to each when making market-based rate authority determinations. The following comments from EPSA address the breadth of the comprehensive market power test before the Commission.

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