August 21, 2012
I support the proposed relief from the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) swaps provisions for certain electricity-related transactions entered into on markets administered by regional transmission organizations (RTOs) or independent system operators (ISOs). The relief responds to a petition filed by a group of RTOs and ISOs.
Congress directed the CFTC, when it is in the public interest, to provide relief from the Dodd-Frank Act’s swaps market reform provisions for certain transactions on markets administered by RTOs and ISOs.
These entities were established for the purpose of providing affordable, reliable electricity to consumers within their geographic region. They are subject to extensive regulatory oversight by the Federal Energy Regulatory Commission (FERC), or in one instance, by the Public Utility Commission of Texas (PUCT). In addition, these markets administered by RTOs and ISOs are central to FERC and PUCT’s regulatory missions to oversee wholesale sales and transmission of electricity.
The scope of the proposed relief extends to the petitioners for four categories of transactions – financial transmission rights, energy transactions, forward capacity transactions, and reserve or regulation transactions. Each of these transactions are inextricably linked to the physical delivery of electricity.
I look forward to receiving public comment on the proposed relief.
Last Updated: August 21, 2012