FERC Filings

EPSA Comments on GRSI NOI

Conclusion

While supporting the Commission’s efforts to eliminate discrimination and market abuse, EPSA does not feel the routine collection of GRSI data will directly help the Commission’s efforts. Generators would be competitively harmed by the burden of reporting such information and the potential of its disclosure. However, if the Commission pursues GRSI collection, EPSA suggests the Commission convene a technical conference and establish a GRSI template informed by RTO, ISO and market monitor collecting practices that generators can use in regions without organized markets. The technical conference should also be instructive about how or if GRSI can specifically be used to identify discriminatory behavior and market abuse.


Respectfully submitted,


Nancy Bagot, Vice President of Regulatory Policy
Jack Cashin, Senior Manager of Regulatory Policy
Electric Power Supply Association
1401 New York Avenue, NW 11th Floor
Washington, D.C. 20005
202-628-8200

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