From:
Ex Parte Communication
Organization(s):
Not-For-Profit Energy End-User Coalition ("NFPEEU")
National Rural Electric Cooperative Association
American Public Power Association
American Public Gas Association
Large Public Power Council
ACES Power Marketing
National Rural Electric Cooperative Association
Schiff Hardin LLP
Wilmer Cutler Pickering Hale and Dorr LLP ("WilmerHale")
Comment Text:
Meeting with Not-For-Profit Energy End-User Coalition
Wednesday, January 19, 2011
Memo from
Steiner, Jeffrey L.
CFTC Staff :
Dan Berkovitz
Julian Hammar
Lee Ann Duffy
Mark Fajfar
Jeff Burns
Susan Nathan
David Taylor
Irina Leonova
Tom Leahy
Jeff Steiner
Peter Sanchez
External Attendees :
Representing NFPEEU:
Russell Wasson (National Rural Electric Cooperative Association)
Susan Kelly (American Public Power Association)
David Schryver (American Public Gas Association)
Noreen Carter-Roche (Large Public Power Council)
Jeffrey Walker (ACES Power Marketing)
Julie Barkemeyer (National Rural Electric Cooperative Association)
Patricia Dondanville (Schiff Hardin LLP)
Paul M. Architzel (WilmerHale)
Additional Information :
NFPEEU believes its members are in a special situation because they are all non-profit entities and any increased costs they bear must be passed directly to ratepayers (i.e.., they do not have shareholders to absorb losses). Also, in terms of their use of swaps, they are required to enter into a variety of different types of customized swaps to reduce the risks of energy commodity price fluctuations because they are mandated to provide continuous electric service to their customers and must deal with a variety of variable conditions, such as changing weather patterns and different sized customer bases. The swaps they use are mostly energy commodity swaps.
With regard to the real-time public reporting proposed rulemaking, NFPEEU believes it would be difficult for its members to report in real time all of their swaps that are entered into between end users. NFPEEU members would prefer to report the swaps on a quarterly basis; or perhaps some of the larger members could report on a weekly basis. NFPEEU also believes it would be difficult for their members to distill some of their electricity swaps into a standardized form for reporting. NFPEEU believes a phase-in period for the reporting requirement would be helpful.
