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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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    <img src="../images/feldman.gif" alt="Washington Viewpoint by Roger Feldman" border="0" width="375" height="75"><p><b><u><br>
      October 2001</u><br>
      </b></p>
    <p><font size="6">Wagon Train</font></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:
    200</em>1/01/19)<br>
    </font></p>
    <p class="MsoNormal"><span style="font-family: Palatino">As the power 
    buckboard rides faster and faster into the new frontier of deregulation, the 
    local marshals are taking a worried look at whether the wheels of the wagon 
    are sound.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">It looks like the 
    buggy may get jacked up for repair soon. It&#8217;s no less important a matter 
    than getting deregulation fixed so that there is no rationale for return to 
    re-regulation further down the trail.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">At the core of 
    electric industry restructuring is the availability of market-based rates (MBR) 
    for new power generation. What PURPA did for IPPs, MBR does in significant 
    measure for merchant generation in growth markets.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">While MBR is not 
    granted without FERC review, the standards have proved to be readily met. 
    Briefly, these include either no ownership of transmission, or no 
    anti-competitive control over transmission, with control most notably 
    mitigated through open access transmission tariffs; showing of no affiliate 
    abuse or reciprocal dealing with parent entities; and the absence or 
    mitigation of market power in generation.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">Essentially the 
    same rules apply with respect to the rates for acquired divested utility 
    generation: MBR authorization is usually sought by asset buyers, and is 
    often granted on the same terms as MBR authority for new generation, with 
    particular attention to market power issues.&nbsp;</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">This last issue has 
    in the past been resolved by the commission through the folksy application 
    of &#8220;hub-andspoke&#8221; analysis, i.e. measurement of relevant market shares in 
    both installed capacity and uncommitted capacity, relative to particular 
    point-to-point service. This is approximately the test for separate wagon 
    service on a series of separate roads, each considered independently of all 
    the other adjacent roads and wagon traffic that a late 19th century bronco 
    trust buster might apply. Not surprisingly, there have been fewer than 10 
    MBR rejections out of over 800 MBR applications. FERC tacitly acknowledges 
    that in its regulations the hub-and-spoke test is so likely to be satisfied 
    that, since 1996, most new generators have been almost automatically 
    entitled to MBR treatment and need not even show the marshal how their 
    hub-and-spoke road will carry wagons.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">This was, of 
    course, the idea: the MBR hub-andspoke test was supposed to be a step toward 
    competitive &#8220;deregulation.&#8221; It was supposed to both promote the blooming of 
    a thousand private power-pumping flowers and lever open the integrated 
    generation-transmission systems of vertical utilities. The approach 
    certainly has begun to work &#8211; with just one drawback wildly demonstrated in 
    California. It is possible to have ferocious consumer-painful price swings 
    in an economically competitive market (at least from a hub and- spoke MBR 
    standpoint) due to the way that market is regulatorily structured, since 
    market power can be exercised by some players at least at some times with 
    respect to their plants. It&#8217;s hard to ignore the evidence of the California 
    experience. It&#8217;s also hard to structure a better MBR mousetrap for 
    anti-competitiveness. But that&#8217;s going to happen soon, as current thinking 
    about market structure and about appropriate competitive screens to 
    determine market competitiveness rise higher and higher in the FERC&#8217;s 
    consciousness.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">The last trail 
    marker, before this new policy perspective is enacted, may be Huntington 
    Beach Development LLC (FERC Docket No. ER01-2390-000), involving the MBR 
    application to FERC of facilities restored by AES to provide additional 
    capacity to power starving Southern California. Seeking cost-based rates as 
    the only measure for what is &#8220;just and reasonable&#8221; under Federal law 
    (&#8220;re-regulation&#8221; in today&#8217;s jargon), the California Commission sought to 
    resist, alleging that applicable affected markets had not been demonstrated 
    to be &#8220;workably competitive&#8221; nor AES to have shown that it lacked market 
    power, in light of its ownership of multiple facilities in the region.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">To which the 
    Commission (then in transition to its current make-up), coyly and 
    cryptically allowed that &#8211; in its florid mating ritual with California 
    market realities &#8211; it was &#8220;not prepared to abandon the hub-and-spoke 
    analysis in favor of another market analysis framework.&#8221; The rationale: the 
    temporary market mitigation measures ultimately established by FERC in 
    response to the California crisis (caps to you and me) would put the 
    Huntington facility&#8217;s rates within the newly-sanctioned &#8220;zone of 
    reasonableness.&#8221; The probable pragmatic rationale: we need more generation 
    in California and won&#8217;t get it if only cost-of-service rates are made 
    available. Of course, the FERC market mitigation measures will expire in 
    2002, leaving both regulatory &#8220;reasonableness&#8221; and appropriate MBRs for 
    services after that expiring rate limbo.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">But while 
    Huntington served as a stopgap answer to a then pending problem, the 
    concurring opinions in the case point the direction to where the 
    Commission&#8217;s focus probably will be heading. Commissioner Massey, in 
    dissent, derided the hub-and-spoke standard as &#8220;anachronistic and 
    unreliable,&#8221; and mocked the Commission&#8217;s suggestion that the new quarterly 
    filing requirements provided (or even were intended by FERC to provide) 
    satisfactory monitoring capability. Then newlyappointed Commissioner 
    Brownell, in her concurrence, articulated what is likely to be the 
    Commission&#8217;s new focus: &#8220;Experience indicates that a methodology that not 
    only looks at individual market shares, but also examines the market itself, 
    would be a far superior method.&#8221; What the new methodology or methodologies 
    adopted by FERC may be currently is problematic. The Commission is still 
    reviewing staff reports on the issue at press time. But as Commissioner 
    Brownell emphasized, it will likely tie into assessment of the larger 
    overall market characteristics, including attention to enhanced regulatory 
    market monitoring and enforcement policies. &#8220;The market&#8221; may come to be the 
    proposed new RTO regions. In short, in the near term, given regulatory 
    uncertainties, it could be tougher to get MBRs. In the long term, in legal 
    principle, existing MBRs could be subject to new challenge, up to and 
    including the cancellation by FERC of MBRs and the imposition of cost-based 
    rates.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">Which creates the 
    following paradox: the current system really doesn&#8217;t address de facto market 
    power.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">If care is not 
    taken, however, the new standard could be tied to the possibly utopian 
    market regulatory models the Commission is now engrafting onto its RTO 
    policy. Those may take a while to actually implement. Even then, if care is 
    not taken, policies could be instituted which do not serve to address the 
    root of much de facto market power &#8211; insufficient transmission 
    infrastructure and inadequate attention to congestion pricing issues. In 
    effect, if care is not taken, the effort to better open markets to 
    competition could create barriers to the very development it sought to 
    encourage.</span></p>
    <p class="MsoNormal"><span style="font-family: Palatino">So, we should all 
    watch carefully this wagon train meander on as its wheels turn, trusting 
    neither to its antique hubs and spokes nor yet to the vagaries of promised 
    virtual and perpetual motion arising from new complex market tests.</span></p>
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    <p class="MsoBodyText" align="left" style="margin-bottom:0in;margin-bottom:.0001pt;
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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