Among the comments filed in response to the FERC technical conference on wholesale market competition, were remarks submitted by the District of Columbia Office of the People’s Counsel, Old Dominion Electric Cooperative, Maryland Office of the People’s Counsel, and Pennsylvania Office of Consumer Advocate. (Here is the Energy Legal Blog overview of the technical conference.)
The “Joint Commenters” reviewed 28 studies that assess current RTO/ISO wholesale power markets:
Although the study results differ, it is important to note that they are not useless; there is still tremendous value that can be derived from these conflicting views. Each of the studies is beneficial in identifying areas that require future study. However, these competing studies remind us that we must do our own due diligence and seek to objectively assess success or failure.
So you can do your own due diligence, I have included their list of 28 studies below. Most of these studies can easily be found online.
The activist group Public Citizen made its case in federal court Wednesday for a requirement that all wholesale electricity rates be filed in advance and assessed on how reasonable they are, rather than blanket approvals being issued for fluctuating market-based rates in competitive markets.
Public Citizen told the US Court of Appeals for the District of Columbia Circuit that the Federal Energy Regulatory Commission is failing to exercise its responsibilities under the Federal Power Act to assure that rates are just and reasonable. …
[Public Citizen attorney Lynn Hargis said] that market behavior rules were not enough, because they did not control rates. “Whether you like it or not, [Congress] has chosen rate regulation,” she said, and that required FERC to assess filed rates, not rely on behavior rules, in her view.
Via Platts (registration required).
For another perspective on what needs to be done now in federal wholesale power markets policy, try Paul Joskow’s remarks delivered at FERC’s technical conference on competition in wholesale power.