The purpose of this page is to enable CREPC members to rapidly share comments and observations on FERC’s proposed Standard Market Design (SMD) rule. The purpose is not to develop common west-wide comments. The outline of the page follows FERC’s proposed rule. Sections of the proposed rule are hyperlinked to this page as are the comments and observations of CREPC members. CREPC members are encouraged to email WIEB staff (sharon@westgov.org) your draft comments and observations. Based on your instructions we can post these anonymously or with information on how to contact the author. Following the section on the proposed rule and CREPC member comments, are formal comments filed with FERC by Western organizations.
Elements of FERC's proposed SMD rule
Western organizations' comments filed with FERC
Testimony on SMD before the Senate Committee on Energy & Natural Resources. (from Sept. 17)
The
following parties filed first-round SMD comments with FERC. The deadline
was November 15, 2002. Second round comments addressing market design for the Western Interconnection; transmission planning and pricing, including participant
funding; Regional State Advisory Committees and state
participation; resource adequacy; and CRRs and transition issues are not due until January 10,
2003. To
view comments, go to FERC’s FERRIS general search engine at http://ferris.ferc.gov/idmws/search/fercgensearch.asp.
Check “Submittal”, enter Docket Number RM01-12, choose
“Comments/Protest” for the Class and “Rulemaking Comment” for Type,
enter the organization’s name as listed below in the Text Search field and hit Submit. ABB
Inc.
Washington
Utilities and Transportation Commission
(pdf)
Western
Interstate Energy Board
(pdf)
RTO
West Utilities (Boise FERC SMD meeting) (pdf)
CREPC
Working Papers - 09/06/02 (pdf)
FERC
SMD Comments - 08/30/02 (pdf)
FERC
EIS Review - 08/30/02 (pdf)
First-Round SMD Comments Filed with FERC
AES Corporation; AES Londonderry, LLC; AES Eastern Energy, L.P.; AES Placerita,
Inc.; AES Wolf Hollow, L.P.; and Indianapolis Power & Light Company
Affiliated Tribes of Northwest Indians
Alabama Electric Cooperative Inc.
Alabama Public Service Commission
Alcoa Inc., et al.
Allegheny Energy Supply Co. LLC and Allegheny Power
Alliance for Rural America
Alliant Energy Corporation
Alstom ESCA Corporation
Ameren Corporation
American Antitrust Institute
American Electric Power Service Corp.
American Forest & Paper Association
American Municipal Power-Ohio, Inc.
American National Power, Inc.
American Public Power Association
American Superconductor
American Transmission Company LLC
American Wind Energy Association
Arizona Corporation Commission
Arkansas Cities
Arkansas Cities - Executive Summary
Arkansas Cities - Executive Summary
Arkansas Electric Cooperative Corporation
Arkansas Public Service Commission
Arkansas River Power Authority
Arkansas River Power Authority - amended
Associated Electric Cooperative, Inc.
Association of California Water Agencies
Basin Electric Power Cooperative
Big Rivers Electric Corp.
Buckeye Power
California Department of Water Resources - State Water Project
California, Public Utilities Commission of the State of
Calpine Corporation
Canadian Electricity Association
Canadian ElectriCity of Association
- Amended comments
Canby Utility Board
Carnegie Mellon Electricity Industry
Center
Center for Biological Diversity
Central Electric Cooperative, Inc.
Central Illinois Light Company
Central Montana Electric Power Cooperative, Inc.
Central Vermont Public Service Corp. and Vermont Electric Power Co., Inc.
Charlene C. Voige
Cinergy Services, Inc.
City of and County of San Francisco
City of Fayetteville, North Carolina, Public Works Commission of the
City of New Orleans, Council of
City of Palo Alto, California
City of Santa Clara
City of Seattle
CMS Energy Corporation
Coalition for Standard Market Design
Cogeneration Association of California and Energy Producers & Users
Coalition
Colorado Association of Municipal Utilities
Colorado Office of Consumer Counsel, New Mexico and Rhode Island Attorneys
General, Utah Committee of Consumer Service, Public Utility Law Project,
National Consumer Law Center
Colorado Public Utilities Commission
Colorado Springs Utilities
Columbia River Inter-Tribal Fish Commission
Connecticut Attorney General's Office
Connecticut Attorney General's Office -
Notice of Correction
Connecticut Dept. of Public Utility Control
Consolidated Edison Energy, Inc.
Constellation Energy Group, Inc.
Consumer Federation of America & Consumers Union
Continental Cooperative Services
CREDA
Crescent Moon Transmission Owners
D.C. Office of the People's Counsel
Dairyland Power Cooperative
Dawson Public Power District
Delaware Municipal Electric Corporation
Dominion Resources, Inc.
Dr. Jian-zhong Zhong, PhD, Shanghai Jiaotong University, China.
DTE Energy Company
Duke Energy Corporation
Dynegy Power Marketing, Inc.
E Cubed Company, LLC
East Kentucky Power Cooperative, Inc.
East River Electric Power Cooperative
East Texas Cooperatives
Edison Electric Institute
Edison Mission Energy
Electric Consumers Alliance
Electric Power Research Institute (EPRI)
ElectriCities of North Carolina, Inc.
Electricity Consumers Resource Council, American Iron and Steel Institute, and
American Chemistry Council (Industrial Consumers)
Electricity Consumers Resource Council, The Transmission Dependent Utlity
Systems, Great River Energy, Buckeye Power, Inc., Wolverine Power Supply
Cooperative, Inc. and The East Texas Cooperatives on Market Power Mitigation
Issues
Electricity of Consumers Resource
Council, et al. with signed affidavit
Electronic Scheduling Collaborative
EnCana Corporation and Energy Services Inc.
eNMART Corp
eNMART
Corp. - attachment
ENMAX Corporation
Entergy Services, Inc.
EPSA, CIEA, EPGA, IEP, IPPNY, MWIPS and WPTF
Excelergy Corporation
Exelon Corporation
FirstEnergy Corp.
Florida Legal Services
Florida Phosphate Council and Florida Industrial Cogeneration Association
Florida Public Service Commission
Georgia Public Service Commission
Georgia Transmission Corporation
Golden Energy Services, Inc.
Golden Northwest Aluminum, Inc.
Great Lakes Utilities, Wisconsin Transmission Customer Group and Municipal
Wholesale Power Group
Great Northern Power Development L.P.
Great River Energy
GreenBuilt Consulting
H.Q. Energy Services (U.S.), Inc.
High Plains Power, Inc.
Hydro Quebec TransEnergie
ICNU
Illinois Commerce Commission
Independent Electricity Market Operator
Indiana Utility Regulatory Commission
Indiana Utility Regulatory Commission, Iowa Utilities Board, Minnesota
Department of Commerce, Missouri Public Service Commission, North Dakota Public
Service Commission, Oklahoma Corporation Commission
Industrial Energy Consumer Group
Interim Joint Committee on Agriculture
Interruptible Industrial Intervenors
Invensys Home Control Systems
Iowa Utilities Board
ISO New England Inc.
Jacksonville Electric Authority
John D. Chandley and William W. Hogan
Kansas City of Power & Light
Company
Kansas Corporation Commission
Kansas Renewable Energy Working Group
KEMA Consulting
Kenneth R. Voige
Kentucky Industrial Utility Customers
Kentucky Public Service Commission
Kentucky, Commonwealth of - Attorney General's Office
Kentucky, Governor Paul E. Patton
KeySpan
Lakeland Electric, Kissimmee Utility Authority, Gainesville Regional Utilities
and the City of Tallahassee, Florida
Large Public Power Council
LG&E & Kentucky Utilities
Long Island Power Authority and LIPA
Los Angeles Department of Water and Power
Louisiana Public Service Commission
Maine Public Service Company
Manitoba Hydro
Maryland People's Counsel
Massachusetts Attorney General, the Connecticut Office of Consumer Counsel, the
Maine Public Advocate and the New Hampshire Office of Consumer Advocate,
together the New England Advocates, (“NE Advocates”)
Massachusetts Dept. of Telecommunications and Energy
Massachusetts Division of Energy Resources
Mathew J. Morey and Eric Hirst
Mercatus Center & Reason Foundation
MG Industries
Michigan Attorney General's Office and the Michigan Public Service Commission
Michigan Public Power Agency, Michigan South Central Power Agency, and the City
of of Wyandotte, Michigan
MidAmerican Energy Company
MidAtlantic & Midwestern Consumer Advocates
MidAtlantic & Midwestern Consumer Advocates - Executive Summary
Mid-Atlantic Conference of Regulatory Utility Commissioners
Mid-West Electric Consumers Association
Midwest Energy Inc.
Midwest Independent System Operator
Midwest ISO Transmission Owners
Minnesota Department of Commerce
Minnesota Power
Mirant Americas, Inc & Mirant Americas Energy Marketing, LP
Missouri Public Service Commission
Missouri River Energy Services
Mitsubishi Electric Power Products, Inc.
Modesto Irrigation District
Montana-Dakota Utilities Co., Inc.
Morgan Stanley Capital Group Inc.
Multiple Intervenors
Municipal Electric Utilities Association of NY
National Electrical Manufacturers Association
National Energy Marketers Association
National Grid USA
National Mining Association
National Rural Electric Cooperative Association
National Rural Electric Cooperative Association identified certain errors in the
11/5/02 filing comments and request that FERC replaces pages 9, 45, and 81 of
the comments
Navajo Tribal Utility Authority
Nebraska Public Power District - corrected version
Nespelem Valley Electric Cooperative Inc.
Nespelem Valley Electric Cooperative Inc.
Nettie H. Roberts
Nevada Independent Energy Coalition and the Cogeneration Coalition of Washington
New England Conference Public Utilities Commissioners, Inc.
New England Consumer-Owned Entities
New England Power Pool Participants Committee
New England Renewable Power Producers
New Horizons Group, Inc - supplement
New Horizons Group, Inc.
New York Independent System Operator, Inc.
New York State Attorney General's Office
New York State Department of Public Service
New York State Reliability Council, LLC
New York State Reliability Council, LLC - corrected version
New York Transmission Owners
Newcorp Resources Electric Cooperative
NiSource Inc.
North American Electric Reliability Council
North American RTO's & ISO's - joint comments
North Carolina Utilities Commission, Public Staff-North Carolina Utilities
Commission, and the Attorney General of the StateNorth Carolina
North Central Electric Cooperative, Inc.
North Dakota Public Service Commission
Northeast Power Coordinating Council
Northeast Utilities
Northern California Power Agency
Northern Maine Independent System Administrator
Northwest Iowa Power Cooperative
Northwest Power Planning Council
Northwest Requirements Utilities and PNGC Power
Nova Energy Consultants, Inc on behalf of North Carolina Towns
NRG Energy - (Attachment 1)
NRG Energy, Inc.
NSTAR Electric & Gas Corp.
Nxegen, Inc.
NYS Consumer Protection Board
Oasis Standards Collaborative
Oglethorpe Power Corporation
Ohop Mutual Light Company - Part 1 of 5
Ohop Mutual Light Company - Part 2 of 5
Ohop Mutual Light Company - part 3 of 5
Ohop Mutual Light Company - Part 4 of 5
Ohop Mutual Light Company - Part 5 of 5
Oklahoma Gas & Electric Co.
Old Dominion Electric Cooperative
Ontario Power Generation Inc.
Open Access Technology International Inc.
Ormet Primary Aluminum Corp.
Otter Tail Power Company
Otter Tail Power Company
Pacific Northwest Utilities' Joint Comments
Peabody Energy
Pennsylvania Public Utility Commission
PG&E Corporation
PHI Companies (Operating Companies of Pepco Holdings, Inc.)
Pinnacle West Capital Corporation
PJM Interconnection L.L.C.
PJM Transmission Owner Group
PJMICC
Platte River Power Authority
Plug Power
Portland General Electric Company
Potomac Economics
PPL - Part I
Progress Energy
PSEG Companies
Public Power Council
Public Service Commission of Wisconsin
Public Service Company of New Mexico
Public Utilities Commission of Nevada
Public Utilities Commission of Ohio
Public Utility Law Project
Redding Electric Utility
Reedy Creek Improvement District
Reliant Resources, Inc.
Ridge Energy Storage & Grid Services, LP
Sacramento Municipal Utility District
Salt River Project Agricultural Improvement and Power District
Seminole Electric Cooperative, Inc.
SeTrans Sponsors
Shmuel Oren, University of California at Berkeley
Siemens Corporation
Sierra Pacific Power Company
Small Business Alliance for Fair Utility Regulation, California Small Business
Association and California Small Business Roundtable
Sorgo Fuels & Chemicals
South Carolina Electric & Gas Company
South Carolina Public Service Authorit
South Carolina Public Service Commission
South Carolina, Public Service Commission of the State of
South Dakota Public Utilities Commission
South Mississippi Electric Power Assoc.
Southeastern Electric Reliability Council
Southern California Edison Company.
Southern Company Services, Inc.
Southwestern Power Administration
Stagetic Power Management Inc.
Steel Manufacturers Association
Strategic Energy
Sunflower Electric Power Corporation
Tennessee Regulatory Authority
Tennessee Valley Authority
Tennessee Valley Public Power Assn.
Texas Office of Public Utility Counsel
Texas, Public Utility Commission of
The Empire District Electric Company
The National Wind Coordinating Committee
The Nebraska Public Power District
The Progress & Freedom Foundation
TransConnect - on a Data Hosting Service implementation, Data Standards in
Support Modular Software Development & SMD.
Trans-Elect, Inc.
TransEnergie U.S., Ltd.
TRANSLink Development Company, LLC
Transmission Access Policy Study Group -
Overview of position and principles
Transmission Access Policy Study Group - on Specific SMD Preamble and Tariff
Issues
Transmission Agency of Northern CA
Transmission Dependent Utility Systems
TXU Operating Companies
U.S. Federal Trade Commission
Union County Electric Coop, Inc.
United Illuminating Co.
United States Bureau of Reclamation
US Congressman Peter DeFazio
US Environmental Protection Agency
US Senator Mary Landrieu
Utah Associated Municipal Power Systems
Utah Municipal Power Agency
Utah Public Service Commission
VA State Corporation Commission
Verendrye Electric Cooperative, Inc.
Vermont Public Power Supply Authority
Vermont Public Service Board
Wabash Valley Power Association, Inc.
Washington Food Industry
Washington State Attorney General
Washington Utilities & Transportation Commission and
North Carolina Utilities Commission
Westchester, NY, County of, and its Public Utility Service Agency
Westconnect RTO, LLC Applicants
Western Area Power Administration
Western Business Roundtable
Western Montana Electric G&T Cooperative
Williams Companies, Inc. - comments
"Williams Companies, Inc. - attachment Market Power Mitigation:
Principles and Practice by Larry E. Ruff, Charles River Associates"
Wisconsin Electric Power Company
Wolverine Power Supply Cooperative, Inc.
WPS Resources Corporation
Xcel Energy