UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
RTO/ISO Credit Principles and Practices } Docket No. AD21-6-000
Credit Reforms in Organized Wholesale Electric Markets } Docket No. AD20-6-000
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
EPSA submits these comments in response to the Notice Inviting Post-Technical Conference Comments on the topics discussed at the staff-led technical conference the Commission convened on February 25 and 26, 2021, to discuss principles and best practices for credit risk management by ISOs/RTOs. The EPSA comments include the principles on ISO/RTO credit rules outlined by Vistra’s Sam Siegel, who participated on a panel on behalf of EPSA, regarding collateral and margin requirements, The comments also support in concept other issues discussed at the conference, including credit-related information sharing among the ISOs/RTOs (currently prohibited by tariffs) and standardizing Know Your Customer (KYC) protocols, including possible centralization of this function, whether through a third-party or housed at one ISO/RTO.