IP and Dynegy

Rick -

Dynegy filed at FERC to protest Com Ed's practice of letting Firm LD ("marketer or financial firm") power qualify as a network resource and therefore be used by marketers for retail contracts. Dynegy says this deprives them of capacity payments that they are entitled to and threatens reliability because adequate reserve margin is not being carried to serve retail load. Dynegy believes retail load must be satisfied using Physical Firm products where specific generation is tied to the retail contract. New Energy and Cilco are the marketers directly implicated.

Enron, Cilco, New Energy, and the ICC have all intervened in support of Com Ed's practice. Our complaint (Susan Lindberg was author) says financial firm is sufficiently, and perhaps even more, reliable than physical firm; and says Dynegy's proposal in effect would create an unneeded ICAP market. The ICC goes on to say Dynegy's proposal would impair retail competition by discouraging entry into the retail market.

Here is the Enron filing -

The other case involving IP is the retail rate case where we have intervened to have IP's request for higher delivery rates dismissed. Our argument is the legal one that their proposal favors bundled customers over unbundled customers. It's the same argument we made in a similar Com Ed case.