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IID Comments to Revised White Paper

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Summary:

Imperial Irrigation District Comments on CAISO’s Proposal for Honoring Existing Transmission Contracts

Extract:

The Imperial Irrigation District (IID) appreciates this opportunity to provide comments on the proposal by California Independent System Operator (CAISO) to honor Existing Transmission Contracts (ETC) in their proposed Market Redesign. The September 20, 2004 White Paper (“White Paper”) and the stakeholder meeting on September 27, 2004, have shown considerable progress in the CAISO proposal since the first draft in March of 2003. The efforts of the CAISO staff to seek stakeholder input over the last few months are to be commended. However, the current proposal still falls short of the Federal Energy Commission’s (FERC) October 28, 2003 Order on MD02 that required ISO to demonstrate that ETC rights holders would not experience a diminution of their contractual rights under the CAISO’s proposal. IID offers the following comments to aid in refocusing efforts to that end.

Document Locations:

• Honoring Existing Transmission Contracts (ETCs)