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Summary:


Mirant Comments, Market Power Mitigation Proposal, October 15, 2004


Extract:

Mirant appreciates the opportunity to provide feedback on the CAISO Market Power Mitigation proposal. We have reviewed the ISO White Paper and the October 7 presentation, and have comments and suggestions. The California market is "back to normal" and CAISO should remove the extraordinary emergency measures imposed in 2001 for "stabilization" purposes ( price cap, must-offer, etc.) There is no indication the existing measures are not working. Therefore, layering a PJM-like mitigation on top of existing measures is oppressive. CAISO should place California back on the same footing as other ISO’s nationwide. At the very least, CAISO should raise the existing damage control bid caps to to be consistent with other markets. Regardless, mitigation should not impede the free workings of capacity markets soon to be implemented by the CPUC.


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