xmlns:o="urn:schemas-microsoft-com:office:office" xmlns:w="urn:schemas-microsoft-com:office:word" xmlns="http://www.w3.org/TR/REC-html40"> Introduction brief for FERC Docket Nopmusserpmusser1462003-03-19T19:59:00Z2003-03-19T20:39:00Z14582616Intertec Publishing21532129.38216 pt22

Introduction brief for FERC Docket No. ER03-262-000:

Exelon and its subsidiary ComEd has filed a motion with FERC suggesting a way to resolve the roadblocks surrounding Regional Transmission Organization (“RTO”) formation and expansion in the PJM Interconnection, L.L.C. (“PJM”) and Midwest ISO (“MISO”) regions. If FERC follows their suggestion; it will resolve the uncertainty now thwarting efforts to expand PJM as a result of Virginia’s actions to stop American Electric Power Service Corporation (“AEP”) from joining PJM, while preserving this Commission’s exclusive jurisdiction over interstate transmission and wholesale energy markets.

Exelon believes that the Commission should immediately grant the pending applications of the New PJM Companies 1 to join PJM. The pending applications include a request for approval of agreements to cede functional control over their transmission systems to PJM and modifications of the PJM tariff to provide for service over those systems. The Commission should accept the applications, but require the New PJM Companies to make a compliance filing to update the proposed rates to account for the delay in the proposed effective date, since the pending rates contemplate a March 1, 2003, effective date. The Commission should require a May 1 effective date for so-called “Day 1” operations (i.e., the date that the New PJM Companies will join PJM and take service under the PJM tariff, as modified by the pending filing). The Commission should also require “Day 2” operations this fall (i.e., the New PJM Companies would be fully integrated into the PJM market). Finally, the Commission should reiterate its vision of having a seamless Super-Regional market including PJM, MISO, and SPP and establish a requirement for it to become a reality by Fall of 2004.

Exelon and ComEd’s suggestion is entirely consistent with the strongly preferred choice suggested in a filing made last Friday, March 14, 2003, by the state public utility commissions of Pennsylvania, Ohio and Michigan.

If the Commission does not follow the suggested route and instead takes the interim step, suggested as a second choice by those state public utility commissions, of requiring AEP simply to contract with a third party such as PJM to operate its transmission system, then the Commission’s goals of integrating PJM, MISO and SPP into a seamless market will remain only a dream for years to come.

1 The New PJM Companies, as identified in this proceeding, include AEP, ComEd, Dayton Power and Light Company (“Dayton”), and Virginia Electric and Power Company (“Dominion”). Dominion is a party to the request for rates pending in this docket, but was intending to proceed separately to join PJM. While we certainly prefer that PJM achieve the full expansion planned, including Dominion, our request here for immediate action on the pending applications to join PJM relates to those pending in this docket, namely those of AEP, ComEd and Dayton.

For the complete filing visit the FERC Online “FERRIS: Federal Energy Regulatory Records Information System” at http://www.ferc.gov/ferris.htm.