Comments of Gini R Cooper requesting that the FERC extend the comment period for the DEIS until the results of a hydrological study of Floyd County is completed re the Dominion Greenbrier Pipeline Project under CP02-396.

Jnofflclal FERC-Generated PDF of 20021118-0001 Received by FERC OSEC 11/15/2002 in D o c k e t # : R M 0 1 - 1 2 - 0 0 0 ~ ORIGINAL UNITED STATF~ OF AMERICA BlFOlgg THE FEDERAL ENERGY REGULATORY COMMISSION RemN~ U~ ~ TIrom~ ) Docket No. R!~1-12-000 o p ~ Acc~m TnmzJm~m Service u d StmNIzrd ) Zkm~Ny M ~ ~ ) NOVEMIER 2002 COMMENTS OF S O ~ CALIFORNIA EDISON COMPANY ON STANDARD ~ T DESIGN NOTICE OF PROPOSED RULEMAKING November 15, 2002 Jnofflclal FERC-Generated PDF of 20021118-0001 Received by FERC OSEC 11/15/2002 in D o c k e t # : R M 0 1 - 1 2 - 0 0 0 .ORIGINAL UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Remedying Undue Discrimination Through ) Docket No. RM01-12-000 Open Access Transmission Service and Standard ) Electricity Market Design ) EXECUTIVE SUMMARY Southern California Edison Company (SCE) has filed limited comments on a few discreet issues raised by the Notice of Proposed Rulemaking (NOPR), but will file comments on the majority of the issues on January 10, 2003, given FERC's deferral of certain issues, particularly those associated with the Western ln~erconnection. On the issue of the Interim Tariff(NOPR IV.A), SCE primarily focuses on the issue of rollover rights, which are inappropriate to grant in circumstances where the services provided under an existing contract are not consistent with the services that would be offered under a new market structure. Specifically, Standard Market Design (SMD) should not permit ITPs to recognize rollover rights for existing transmission contracts (ETCs) or firm transmission rights (FTRs), as granting rollover rights would lead to inefficiencies and are not congruent with the market structure envisioned under SMD. Allowing ETC customers to exercise rollover rights would cause additional phantom congestion and result in unreasonable subsidies. In response to Section IV.B of the NOPR, SCE points out a major flaw in the NOPR - its lack of consideration of the effects of the NOPR on the most important source of new transmission investment - existing transmission owners (TOs). This flaw is not limited to the NOPR; recent FERC policy decisions have inappropriately harmed the financial health of these key industry players by saddling TOs with unrecoverable costs through "cost trapping." The robust transmission grid FERC seeks cannot be obtained without adopting policies that ensure adequate cost recovery opportunities. SCE urges the Commission to adopt a transmission business model that will promote effective transmission development by assigning clear responsibility and accountability for transmission expansion planning to the independent transmission providers (...