Docket No.: EL10-56-000, et al.
The Western Power Trading Forum (WPTF) and the Electric Power Supply Association (EPSA) jointly filed a letter at the FERC to raise on behalf of their respective members several grave concerns regarding the approach the Commission has taken in a series of recent orders on filings by sellers justifying sales that exceeded the WECC Soft Offer Cap that were filed in October 2020. In the near term, the Western Interconnection is forecast to be the most resource constrained area in the United States. Depending on weather and hydro conditions over the course of this summer and for the next few years, this may result in periods which could cause power interruptions in CAISO like those seen in August 2020 as well as very high prices in neighboring parts of WECC. Under such circumstances WPTF and EPSA respectfully request that the Commission recognize: 1) the misapplication of an ICE weighted average index as dispositive for justification of exceedance of the Soft Offer Cap, 2) the Commission’s adherence to the Mobile-Sierra standard (absent a public interest determination) as it applies to freely negotiated bilateral contracts in order to provide the certainty which supports reliability, and 3) that the WECC Soft Offer Cap should be harmonized with the caps available to an adjacent RTO under Order No. 831.
