FERC Filings
REQUEST FOR REHEARING OF JULY 25 REFUND ORDER
- I. ORDERING RETROACTIVE REFUNDS TO OCTOBER 2, 2000 IS LEGALLY FLAWED AND INAPPROPRIATE
- II. THE COMMISSION HAS SET FORTH A FLAWED PROCEEDING FOR THE PACIFIC NORTHWEST. POTENTIALLY ORDERING REFUNDS BASED ON THESE PROCESSES IS RETROACTIVE RATEMAKING IN VIOLATION OF THE FILED RATE DOCTRINE
- III. THE COMMISSION DID NOT ADDRESS THE CONCERNS OF MARKETERS THAT ORDERING REFUNDS BASED ON A PROXY PRICE SET BY A GENERATOR IS INAPPROPRIATE
- IV. CONCLUSION