I am writing to express my concern over the Feb. 1 publication of the article, "Why Applicants Should Use Computer Simulation Models to Comply With FERC's New Merger Policy" (p. 22). The authors, Mark W. Frankena and John R. Morris, have used the editorial pages of PUBLIC UTILITIES FORTNIGHTLY to deliver a highly commercial message promoting their preferred computer model at the expense of several other software packages, which they specifically name. We are disappointed that PUBLIC UTILITIES FORTNIGHTLY would allow the authors to discredit the products of other companies with unsubstantiated claims and generalizations.

First, the authors state that the disadvantage of load flow/dispatch models such as MAPS is evident: "They require large amounts of data, many of which are not publicly available." In fact, the data required by MAPS is precisely the reason why the model delivers increased accuracy over transportation models, which do not take into account the physical characteristics of electricity. Contrary to what the authors state, this information is available at the

Federal Energy Regulatory Commission in FERC Form 715. At GE, we have the data needed to analyze most of the NERC regions in the U.S. [regional reliability councils of the North American Electric Reliability Council]. The statement that the detailed modeling "may not produce better results than obtained using simpler models," may be countered by the statement that it almost always does, and for transactions involving millions of dollars, this improved accuracy is essential.

Second, the statements by the authors concerning low-voltage lines clearly demonstrate their lack of knowledge or experience using MAPS, since this software does include models of low-voltage lines. In fact, we can model up to 20,000 lines. And contrary to what the authors state, we do model operating guidelines.

Finally, the statement that "these models were not developed to analyze market power" is grossly inaccurate. MAPS is a tool that has evolved to assist our customers in gaining a competitive advantage in the deregulated market. By accurately modeling the transmission system, including its

constraints, bottlenecks and congestion, the user gets a true picture of the environment in which significant financial transactions will take place. Obviously, the transportation model is not capable of portraying such a picture. At GE, we can make this comparison since we successfully developed a transportation model over 10 years ago.

MAPS is currently being used in pending mergers and to evaluate issues such as stranded generation investments. Data from MAPS has been used in expert testimony at public service commission rate cases, and MAPS is considered the deregulation tool of choice by many of our customers.

In closing, we would appreciate your setting the record straight, and conveying this information to the readership of PUBLIC UTILITIES FORTNIGHTLY.

T.F. Garrity,

General Manager,

GE Power Systems

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