EPSA Draft Comments on NYISO Market Mitigation Measures

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