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    <p align="left"><font face="Arial"><strong><small>About The Author:<br>
	<br>
	</small></strong><span lang="X-NONE" style="color: black"><font size="2">
	ROGER FELDMAN, Co-Chair of Andrews Kurth LLP Climate Change and Carbon 
	Markets Group has practiced law related to the finance of environmental and 
	energy projects and companies for 40 years.&nbsp; In particular, he has analyzed 
	and executed a wide variety and substantial value of project financings.&nbsp; He 
	chairs the American Bar Association&#8217;s Committee on Carbon Trading and 
	Finance, serves on the Board of the American Council for Renewable Energy, 
	and has been a senior official in the Federal Energy Administration.&nbsp; He is 
	a graduate of Brown University, Yale Law School and Harvard Business School.</font></span></font></p>
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<!--webbot bot="Include" i-checksum="19883" endspan --><p>&nbsp;</td>
    <td width="75%" valign="top"><img src="../images/feldman.gif" alt="Washington Viewpoint by Roger Feldman" border="0" WIDTH="375" HEIGHT="75"><p><b><u>September
      2000</u><br>
      </b></p>
      <p><b><font face="Arial" size="6">Of Air and Power Rage</font></b></p>
    <p><strong>by Roger Feldman&nbsp; -- &nbsp; Bingham, Dana L.L.P.<br>
    </strong><font face="Arial" size="2">(<em>originally published by PMA OnLine Magazine:
    2000/10</em>)<br>
    </font></p>
      <p ALIGN="JUSTIFY">It was the summer where people packed the airplanes;
      stifled, simmered and suffered; applauded humorists who mocked their fate
      and their &quot;captors&quot;; and began to mull seriously news magazine
      columnists&#8217; suggestion that airline deregulation should give way to
      public-private partnerships When prices went up in a devilishly targeted
      manner, mega- mergers were proposed to achieve efficiency; regulators were
      mocked for their inefficacy in providing computerized management systems
      up-dated to correspond to service levels; the weather was blamed for
      everything, and economists celebrated whole thing as the triumph of
      deregulation. After all, there <u>was</u> more travel and per unit it was
      more efficient. It was the summer of air rage.</p>
      <p ALIGN="JUSTIFY">This, of course would never happen in the electric
      power/natural gas industry. It was the summer when shortages were most
      pronounced in the regions where deregulation had first occurred. Where
      regulators turned to price caps to deal with spikes in power prices; when
      the AGA dusted off its explanation for gas price uses and inventory
      declines (prices it seems had been too low and inventories too high to
      stimulate needed search); and, above all, a summer when a new fear of
      re-regulation stalked the private power industry. (&quot;Deregulation
      sucks&quot; was the headline in a parched San Francisco newspaper). The
      deregulated power supply industry&#8217;s trade association convened a major
      war council to take the lead in developing a response to &quot;spreading
      consumer, political and regulatory concerns about power supply in certain
      areas of the country.&quot; No power rage here.</p>
      <p ALIGN="JUSTIFY">It was the summer before the election, and all of the
      players responded to the crisis admirably. As the notion of comprehensive
      legislation creaked futiley on, older rifle shot ideas - like mandatory
      hard lending deregulation dates, resurfaced with a vengeance. In this
      case, the vengeance (Sen. Schumer) was in part on the Governor (of New
      York) who had administratively deregulated only to discover that
      deregulation could lead to ongoing price escalation (of ConEdison) as real
      wholesale prices became retail prices. Surely, however, someone wise
      reasoned, Federally imposed deregulation would not have that effect in a
      mandated deregulation quilt of fifty state colors... If Congress saw the
      energy crisis as a football it chose not to touch in an election year,
      Chairman Greenspan, unhampered by that constraint, did not feel so
      encumbered. Atlas shrugged (oblivious to the facts it might appear) that
      Congressional inaction on deregulation was making the needs for new
      powerplants unclear; that there was a disincentivization to construction;
      and that instability in the economy therefore might result. One takes
      comfort in knowing that he clearly believes that price increases and other
      power industry perturbations don&#8217;t reflect the increase in natural gas
      prices and will not be impacted in the future at a time when the new fleet
      of plants being built turns out to be all combined cycle gas. Greenspan
      reassured us that it takes a while to get the wells in place and bring up
      the level of inventories of natural gas. That laugh track you hear in the
      background is courtesy of OPEC, by the way folks.</p>
      <p ALIGN="JUSTIFY">Well, at least Greenspan was keeping his eye on that
      old economy supply-demand thing. That&#8217;s better than in strife-form
      California, as PG&amp;E prepared to consummate the State&#8217;s successful
      deregulation by auctioning off its huge, non polluting successful hydro
      system. Two Green powers clashed over this proposition. Each, however,
      promised to downward tilt the supply half of the power equation: Sierra
      Green wants the dams busted so the salmon can swim freely and multiply;
      Dollar Green wants to fragment the PG&amp;E ownership thereby maximizing
      the optionality of individual sites, without reference to what that does
      to the productivity of the system. Even (Sen.) Pease, the deregulation
      sponsor, is now breaking out in hives and publicly suggesting that maybe
      his baby was Rosemary&#8217;s. No power rage here.</p>
      <p ALIGN="JUSTIFY">Fortunately, our national leaders &#8211; at least, our
      presidential candidates &#8211; have clear fixes in mind to fill the vacuum of
      Congressional inactivity and State political paralysis. &quot;W&quot;&#8217;s
      presumptive Secretary of Energy and Commerce, Ken Lay, told Congress to
      get cracking on deregulation (presumably in a manner which was
      conservatively compassionate and conducive to large volumes of trading of
      energy commodities). To hedge his bets, Secretary Presumptive also
      announced his deal with Blockbuster, as well as his new energy marketing
      joint venture with AOL and IBM. His top corporate aide assured us all that
      more power plants were on the way and all would then be well. Vice
      President Gore brought a whiff of &#8216;60&#8217;s eco-incense and &#8216;70&#8217;s
      malaise to the debate, calling for billions of dollars in tax incentives
      to promote new technologies, solar powered homes and cleaner running cars.
      Comforted were we all to learn, that it was a timid old way of thinking to
      trade off the economy and the environment (as to the latter of which his
      commitment &quot;has always run deeper than politics.&quot;)</p>
      <p ALIGN="JUSTIFY">Yet, it was not yet a summer where energy rage joined
      air rage, because we Americans have learned to deal with the depths of
      inability of our leaders to lead and planners to plan. When supply and
      demand are out of whack, while our public procurators posture, we
      organize; we try to smooth imbalances by moving goods; we engage specific
      new technologies to overcome the core of problems as well as the
      discontents of consumers. The kinds of bright spots that will grow that
      saw the light of day this summer:</p>
      <blockquote>
        <ul>
          <li>
            <p ALIGN="JUSTIFY">The City of Chicago (located in a spike impacted
            region) joined with 47 other local governments to aggregate electric
            power loads, in order to seek cheaper power in the competitive
            market. It was advantage of the first opportunity since its State
            deregulation to pursue that route. An RFP was issued with a 20%
            mandatory renewable resource component.<br>
          </li>
          <li>
            <p ALIGN="JUSTIFY">Plans for a major B2B transmission exchange were
            unveiled by AEP, CP&amp;L, Duke and Unicom allowing those seeking to
            reserve and schedule transmission capacity to consolidate
            transactions they currently make on 2 or more OASIS sites. A
            regional exchange in the Carolinas was announced hard on its heels.<br>
          </li>
          <li>
            <p ALIGN="JUSTIFY">Otter Tail Power (which you may know better as
            the owners of the Fargo Red Hawks &#8211; it pays to diversify)
            introduced new real time load management software which allows the
            customer to reduce consumption during critical price event periods,
            and by thereby creating negawatts become a resource to the network.</li>
        </ul>
      </blockquote>
      <p ALIGN="JUSTIFY">Ward Uggerud, energy supply officer and lead developer
      of the technology captured the spirit of all of these innovations &#8211;
      which we can only hope will percolate upwards and color the
      regulation/deregulation energy debate which has gridlocked Washington:
      &quot;I have spent my entire career..dealing with our load control area&#8230;
      The philosophy behind the (customer choice) technology is to take and
      expand those things that load control areas do at the utility level and
      make them available at a retail customer level.&quot;</p>
      <p ALIGN="JUSTIFY">So as we leave the summer furnace and look past the
      election, we are left with the hope that Air Rage will not give way to any
      Power Rage (other than the election), because America&#8217;s market
      adaptation instincts &#8211; as distinguished from Washington&#8217;s formulaic
      recitation of adherence to market based principles without notice of
      mundane consequences &#8211; can prevail within a workable time period.</p>
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text-align:left"><font face="Arial" size="2">
	<span lang="X-NONE" style="color: black">ROGER FELDMAN, Co-Chair of Andrews 
	Kurth LLP Climate Change and Carbon Markets Group has practiced law related 
	to the finance of environmental and energy projects and companies for 40 
	years.&nbsp; In particular, he has analyzed and executed a wide variety and 
	substantial value of project financings.&nbsp; He chairs the American Bar 
	Association&#8217;s Committee on Carbon Trading and Finance, serves on the Board 
	of the American Council for Renewable Energy, and has been a senior official 
	in the Federal Energy Administration.&nbsp; He is a graduate of Brown University, 
	Yale Law School and Harvard Business School.</span></font></p>

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