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Long-Term Transmission Rights: A High-Stakes Debate

The absence of long-term transmission rights could exclude potential competition—and cause higher electricity costs.

Fortnightly Magazine - March 2006

Transmission System Operator, pp. 5-6.

21. Comment of National Grid USA, p. 1.

22. Comment of American Public Power Association, p. 16.

23. Comment of Edison Electric Institute, p. 6.

24. Comment of Southern California Edison, p. 3.

25. Comment of National Grid USA, pp. 20-21.

26. Comment of WPS Resources, pp. 3-4.

27. Comment of Midwest Independent Transmission System Operator, p. 6.

28. Comment of Silicon Valley Power, p. 16.

29. Comment of the Staff of the Federal Trade Commission, pp. 4-5.

30. Comments of National Grid USA, p. 2; and Pacific Gas and Electric, p. 5.

31. Comment of First Energy Solutions, p. 3.

32. Comments of Edison Electric Institute, p. 9; and Midwest Stand-Alone Transmission Cos., p. 9.

33. Comment of Morgan Stanley, p. 4

34. Comment of Midwest Stand-Alone Transmission Cos., p. 4.

35. See, for example, the Comments of American Electric Power; Electricity Consumers Resource Council (ELCON) and the American Iron and Steel Institute; staff of the Federal Trade Commission; Midwest Stand-Alone Transmission Cos.; National Rural Electric Cooperative Association; Organization of MISO States; Silicon Valley Power; and Southwest Power Pool Regional State Committee.

36. Remarks of Audrey Zibelman, Executive Vice President PJM Interconnection, LLC, Docket Nos. AD05-5-000 and PL03-1-000, April 21, 2005, p. 5.

37. Ibid., p. 7.

38. Federal Energy Regulatory Commission, Notice of Proposed Rulemaking, Promoting Transmission Investment through Pricing Reform, Docket No. RM06-4-000, Nov. 17, 2005.

39. Comment of the staff of the Federal Trade Commission, p. 8.

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