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<br />appropriate way to implement these provisions, but has not yet issued any proposed rule. In <br />its comments filed afterthe technical conference, APPA noted that the purpose of the <br />transparency provisions was to make rnarkets work more effectively. Therefore, FF.RG should <br />not focus solely on price indices as determinants of price transparency. Instead, "t.he <br />Commission should broaden its focus to consider how greater availability of market <br />information can improve. price transparency and help address problems in natural gas and <br />electricity-markets." <br />. ~ • , 1 1 <br />FERC has adequate authority to ensm~ejust and reasonable wholesale rates and to obtain <br />information needed to oversee wholesale markets, but needs to exercise this authority more <br />rigorously. Congress can also play a role in encouraging FERC to utilize its existing <br />authorities, especially in the context of RTOs/ISOs. <br /> <br /> APPA supports FERC's initiatives to address generation market power issues through it_s <br /> rnarket-based rate policy review, and its implementation of the market manipulation and <br /> long-term transmission rights provisions under EP.Act05. <br /> <br /> APPA did not support the repeal of PUHCA included in EPAct05, holding to the position <br /> that the preservation of PUHC,A and more active enforcement by the Securities and <br />. Exchange Commission (SF.C) was crucial to achieve effective wholesale competition in the <br /> electric utility markets for the benefit of consumers and the public interest. On the other <br />. hand, APPA strongly supported the market manipulation prohibition and the enhanced state <br /> and federal access to holding company books and records included in EPAct05, as well as <br /> FERC's enhanced authority over holding company and generation-only mergers. APPA <br /> believes that these authorities - if fully enforced -will help to offset the potential for the <br /> exercise of market power created by PUHCA's repeal. T <br /> <br /> <br /> <br />L~ <br />www.APPAnet.org <br />11 <br />