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San Francisco

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Summary:

COMMENTS OF THE CITY AND COUNTY OF SAN FRANCISCO IN RESPONSE TO THE PROPOSED REVISIONS TO THE MRTU LOCAL MARKET POWER MITIGATION PROVISIONS PRESENTED IN THE OCTOBER 1, 2004 WHITEPAPER, October 19, 2004

Extract:

San Francisco submits preliminary comments and requests for clarification with respect to the “CAISO Proposed Revisions to its MRTU Market Power Mitigation Provisions” Whitepaper, dated October 1, 2004 (“Whitepaper”). The Whitepaper covers a wide variety of important market design issues that remain unresolved and under both policy development and discussion in other forums. San Francisco is mindful of the FERC directive from the October 28, 2003, Order tying treatment of Market Power Mitigation directly to the outcome of the CPUC’s resource adequacy proceeding. Specifically, FERC directed the ISO to develop and file a revised Market Power Mitigation Proposal following the issuance of the CPUC’s Resource Adequacy Decision in the CPUC’s R.04-04-003 proceeding.

Document Locations:

• Market Power Mitigation under MRTU