FERC Filings
EPSA's Motion for Leave to Intervene and Comment in Support of Immediate Techinical Conference
Comments
In their June 3 filing, the Independent Generators correctly assert that Entergy’s May 27 filing not only addresses a proposal to establish an Independent Coordinator of Transmission (ICT), but it also sets forth a number of new business processes that are ambiguous in nature and raise numerous questions on the various proposals detailed in Energy’s filing. In order to gain clarity on these questions and Entergy’s plans for the ICT, the new transmission pricing policy and the Weekly Procurement Process (WPP), EPSA believes that a technical conference would benefit all market participants. Moreover, a Commission-sponsored technical conference may, in fact, speed up the process by which these proposals are implemented by allowing all parties involved to be as informed as possible before submitting comments. A technical conference would likely eliminate the need to file requests for clarification in those comments leading to subsequent rounds of answers and comments.
The Independent Generators also point out in their June 3 Filing that prior to its May 27 filing, Entergy never discussed the details of its various new business processes with its stakeholders. In an answer to the Independent Generators filed on June 8, 2005, Entergy proposes to hold a stakeholder meeting on June 21, 2005. EPSA members feel strongly that an Entergy-sponsored stakeholder meeting would not accomplish the same goal as a fair, open, and on-the-record FERC-sponsored technical conference. Because Entergy has officially filed this proposal with the Commission and the Commission has noticed it, the stakeholder process going forward should be convened and conducted by the Commission. The proposals set forth by Entergy are now before the Commission for consideration and, as such, should be discussed in an open forum in the presence of Commission staff.
In the event that the Commission grants the requests for this much needed technical conference, EPSA supports Calpine’s June 7 request for a modest extension to the comment period set forth by the Commission’s June 6, 2005 notice of Entergy’s Section 205 filing. The notice originally sets forth a comment date of June 17, 2005. EPSA requests that comments be due no less than 20 days after the technical conference is held. This should not result in a significant delay, as the technical conference will contribute to a better understanding of all of Entergy’s proposals by all market participants and will result in robust and complete comments from all parties.