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Standards of Conduct Ensure a level playing field, but don’t put electric companies at a competitive disadvantage. FERC has proposed to adopt a single set of Standards of Conduct for both the electric and gas industries that would govern the relationships between regulated transmission providers and all of their energy affiliates – not just those engaged in marketing or sales functions. The proposed Standards would require a separation of functions between the transmission function and a broadly defined category of entities know as “energy affiliates.” Most notably, the definition of “energy affiliate” would require a separation of the transmission function from all sales functions, including bundled retail sales. FERC staff has also recommended the application of the “automatic imputation” rule to shared employees which would likely eliminate the Order No. 889 exemption which permitted the use of shared employees. This could lead to companies having to disaggregate in order to comply. In November 2003, FERC issued a final rule
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