Table 1 Summary of FERC Staff's Deficiency Letters to Other MBR Filings Issued on October 29, 2004 Applicants
Pinnacle West Puget Sound Consumers Southern √ √ √ √
Entergy
Alliant
Deficiency Areas
1 Broader Geographic Market (Need to provide supporting documents)
PSNM
KCPL
Duke
AEP
DPL
[4]
[5]
√
Note These are not ISO\RTO Market definition. [4] Puget defines its market as Pacific Northwest. FERC Staff also requests the tests for the broader market's firsttier [5] PSNM performed the broader market for southern California, southern Nevada, and western Arizona. [6] Need to define "current data" used to conduct its revised analyses.
2 Not Using most recent 12 months data Using Seasonal Capacity instead of Nameplate Capacity 3 (Need to explain why) 4 Affiliate generation as supply of competitors 5 Descrepancies in its calculations/presented data and exhibits 6 Limit import capability to historical peak hour of all seasons Excluding Weekends and Holidays from Load Calculation 7 (Need to explain why) 8 Used wrong load number (e.g. used needle peak for average daily peak) No Deduction of Lt sales firm non-requirement for Applicant' s 9 competitors 10 Request for additional data on RFP and ATC for competing generation
√ √ √ √ √ √ √ √ √ √ √ √
[6] √ √
√ √
11 Other Three-Part Tests Fail to include the revision of FERC's 12 2003 Market Behavioral Rules in the tariff
√ √ √
[2]
[3] √
[2]
[2] DPL and Pinnacle West did not discuss affiliate abuse/reciprocal dealing. [3] Entergy's discussion on other three prongs of market power are inadequate.
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Summary of FERC Staff's Deficiency Letters to Other MBR Filings Issued on October 29, 2004 Applicants
Pinnacle West Puget Sound Consumers Southern √ √ √
Entergy
Alliant
Deficiency Areas
Workpapers of Inputs and Calculations of Two Indicative Screens
PSNM
KCPL
Duke
AEP
DPL
Note [1] For AEP-SPP's first-tier markets and how AEP determined maximum demand of its wholesale load in "truncated market share analysis"
13
[1]
√
√
√
√
√
√
√
14 Explanation of Truncated Analysis Transmission
√ SIL should be by season. * Applicant does not need to submit additional data response requested in Appendix A of the letter if its analysis does not consider imports by competitors.
15 Simplified SIL Studies (Data Request in Appendix A)* 16 SIL Workpapers as required in Appendix E of the April Order Do Applicant and affiliates have firm or network transmission 17 to import remote generation in first-tier markets? If so, they get priority use, remaining then should be pro-rata. Delivered Price Test 1 Load used in AEC calculation 2 Need to separate TDU 3 Multifaceted backup requested Mitigation Request more details on mitigation under PNM's cost-based rates
√ √
√ √
√ √
√ √
√ √
√ √
√
√ √
√
√
√
Issue on treating PV and Redhawk as remote generation but using prorata to bring power of these units inside APS for some seasons.
√ √ √ √
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