MEMORANDUM

TO: Regulatory Affairs Committee
       Power Marketers Working Group

FROM: Jim Steffes, Regulatory Affairs Committee Chair
            Bob Reilley, Power Marketers Working Group Chair
            Julie Simon, Vice President of Policy

DATE: August 14, 2001

RE: EPSA Draft Petition for Rehearing of FERC's July 25th
      California Refund Order

Attached is a draft Petition for Rehearing of the Commission's July 25th Order on refunds for the California and WSCC wholesale markets.  The Petition is largely procedural, focusing on the lack of any finding of abuse of market power or an adequate factual record to order refunds.  We also oppose the Pacific Northwest refund process and argue that marketers should have an opportunity to show their actual costs in any refund proceeding.
Petitions for rehearing are due at FERC on Friday, August 24th.  We will discuss this draft on the weekly conference call this Friday, August 17th.  In addition, please forward any comments or proposed changes to the draft to Julie Simon at jsimon@epsa.org no later than noon on Wednesday, August 22nd so that we can make this filing is a timely manner.  If you have any questions or concerns, please contact Julie at 202-628-8200.

Attachment


 - July 25 rehearing final.doc