Message-ID: <32089121.1075860449422.JavaMail.evans@thyme> Date: Mon, 26 Mar 2001 09:36:00 -0800 (PST) From: jgallagher@epsa.org To: bhawkin@enron.com, bmerola@enron.com, christi.l.nicolay@enron.com, donna.fulton@enron.com, janelle.scheuer@enron.com, jeff_brown@enron.com, jhartso@enron.com, jsteffe@enron.com, mary.hain@enron.com, rshapiro@enron.com, sarah.novosel@enron.com, tom.hoatson@enron.com Subject: EPSA Draft Comments on NYISO Market Mitigation Measures Mime-Version: 1.0 Content-Type: text/plain; charset=ANSI_X3.4-1968 Content-Transfer-Encoding: 7bit X-From: "Jackie Gallagher" X-To: , , , , , , , , , , , X-cc: X-bcc: X-Folder: \Mary_Hain_Aug2000_Jul2001\Notes Folders\Notes inbox X-Origin: Hain-M X-FileName: mary-hain.nsf MEMORANDUM TO: Regulatory Affairs Committee Power Marketers Working Group FROM: Joe Hartsoe, Regulatory Affairs Committee Chair Bob Reilley, Power Marketers Working Group Chair Julie Simon, Vice President of Policy Erin Perrigo, Manager of Policy DATE: March 26, 2001 RE: EPSA Draft Comments on NYISO Market Mitigation Measures ? Filings Due on Friday, March 30th The New York Independent System Operator, Inc. (NYISO) has filed requests to extend both its Temporary Extraordinary Procedures (TEP) for Correcting Market Design Flaws and Addressing Transitional Abnormalities (Docket No. ER01-1489-000, comments due March 30, 2001), and its current bid caps for certain NYISO markets (Docket No. ER01-1517-000, comments due April 2, 2001) for an additional 18 months. The ISO also filed a Notice of Withdrawal of its October 20, 2000 filing in ER01-181-000, and introduced its intent to implement a circuit breaker mechanism under its current Market Mitigation Plan, as approved by FERC (comments due March 30, 2001). Attached are EPSA's draft comments in response to all three cases. The draft focuses on the use of price correction mechanisms and the unintended, yet harmful, consequences on the market such as limiting market entry, slowing the development of risk mitigation tools, and undermining demand-side response. EPSA's comments also argue that the NYISO should make an official filing to the Commission introducing its circuit breaker proposal under o205 or 206 of the Federal Power Act. Please review the attached draft and forward any comments or suggestions to Erin Perrigo at EPSA at 202-628-8200 or eperrigo@epsa.org as soon as possible. Comments must be filed by March 30th. We will discuss the draft comments on our conference call this Wednesday , March 28th, at 2:00 p.m. (EST). To access the call, dial 1-800-937-6563. Ask for the Julie Simon/EPSA Call. Attachment - NYISO Consolidated Market Mitigation Filing.doc