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Williams

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Summary:

CAISO Proposed Market Power Mitigation Williams Comments, October 2004

Extract:

Williams appreciates the opportunity to comment on CAISO’s proposed Market Power Mitigation (MPM) provisions, as described in CAISO’s white paper released October 1, 2004 and at the Stakeholder meeting on October 7. Williams has a number of concerns and cannot support the CAISO MPM provisions as currently constructed. Williams reserves the right to raise additional issues regarding Market Power Mitigation as CAISO market design stakeholder process continues. General Concerns: CAISO has incorporated nothing to address the economic realities of the value of incremental capacity. Subsequent to the release of the CAISO white paper, CAISO had the opportunity to hear consistent advice from experts involved in the design of eastern markets, shared at the CPUC/CAISO/CEOB Capacity Conference in San Francisco earlier this month. Williams urges CAISO to consider and incorporate this advice in its next version of the MPM proposal. If CAISO does not do so, its proposed excessive mitigation will send the wrong signals to the market and investment community. To recap the consensus wisdom:

Document Locations:

• Market Power Mitigation under MRTU