Electricity Market Design and Structure: Working Paper on Standardized Transmission Service and Wholesale Electric Market Design

These comments are submitted on my own behalf in connection with the Commission's deliberations on the "Federal Energy Regulatory Commission Working Paper on Standardized Transmission Service and Wholesale Market Design," (working paper) distributed March 15, 2002. Development of a standardized market design that can support a competitive electricity market is an important task that this Commission is right to undertake with vigor. As I have testified before, the current situation of a half complete restructuring of electricity markets is less likely to meet the needs of the nation than either the highly regulated world of the past or the more market-oriented approach to which we aspire. We should not stay where we are today. The status quo will support neither efficient operations nor adequate investment. It is very difficult to see how to go back the world that existed before passage of the Energy Policy Act of 1992, even if this were desirable. Hence, the best option is to go forward with a sound restructuring of electricity markets. To move forward, certain institutions will be needed that require the Commission's design and support.

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