FERC Filings
SUPPLEMENTAL COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: INVESTIGATION OF TERMS AND CONDITIONS OF PUBLIC UTILITY MARKET-BASED RATE AUTHORIZATIONS
- THERE IS NO IDENTIFIED PROBLEM FOR THIS “SOLUTION”
- A BLANKET REFUND CONDITION IS NOT SOUND OR LEGAL
- THE REFUND CONDITION SHOULD NOT APPLY TO MARKETERS
- EPSA IS WILLING TO ACCEPT INTERIM MARKET INTERVENTIONS DESPITE THE NEGATIVE CONSEQUENCES
- INTRODUCTION
- THERE ARE SOUND MEANS OF PROMOTING SUPPLY
- SOLUTIONS SHOULD BE TAILORED TO IDENTIFIED PROBLEMS
- THE CHAIRMAN’S STRAWMAN IS INCONSISTENT WITH A BLANKET REFUND CONDITION
- CONCLUSION