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not likely that RTOs will form in the rest of the country in the foreseeable <br />fuuare. The American Public Power Association (".APPA") believes that <br />RTOs are not the only-and in many regions not the best-strucun-e for <br />providing non-discriminatory transmission access. Thus, regional diversity <br />must be acknowledged, and more pragmatic and flexible federal <br />transmission policies i~nplernented to deal vv~th the. reality "on the ground." <br />It is time to take stock of FERC's electric restructuring policies-some of <br />~~~hicl~t AI'P:~ and its members initially endorsed-and to make badly needed <br />"mid-course corrections" to fix existing RTOs and to encourage non-I2"hO <br />alternatives in those regions ~~here they are not likely to form. A "bottom <br />up" evaluation is needed to ensure [he long-term adequacy of both <br />generation and transmission facilities, in both RTC) and non-RTO regions. <br />Pe~~~ "~ould say that FERC's policies }gave been an unqualified success; many <br />APPA members view them as a failure. APPA fears that a continuation of <br />the "IZTO or nothing" a~~proach and inadequate supervision of existing <br />RTOs will harm consumers and threaten the adequacy of our Nation's <br /><aectric system. <br />FFIZC is charged under the Federal Poker Act ("FPA") ~,~ith ensuring <br />that rates, terms and conditions of service for ~~~holesale electric po~~~er <br />and transmission service are just and reasonable" and not °unduly <br />discriminatorti~." FF,RC needs to examine whether its policies satisfy <br />these statutory requirements and benefit electric consumers-not the <br />independent power producing sector, the existing IZTOs; ISOs, investor- <br />o~~~ned utilities ("IOlis") and their shareholders, or financial institutions. <br />In this paper, _AYP.~~ outlines fundamental policies intended to ensure <br />that electric consumers in tact-not just in economic theory-benelit <br />from 1`ERC's initia[ivcs. It suggests that FIRC reorient its policies to: <br />1 Ensure appropriate investment in long-lived transmission and <br />generation infrastructure; <br />1 Recognize and respect regional differences and preferences in <br />the industry; <br />Encourage cost-effective and not overly complex regional solutions <br />that both fulfill FERC's statutory obligations and meet the needs of <br />a region's diverse stakeholders; <br />2 Restructuring at the Crossroads: FERC Electric Policy Reconsidered <br />