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Public power systems ha~'e long planning horizons and a low tolerance <br />for risk and price volatility. In order to scree their customers reliably <br />and economically, they are required to make long-teen investments and <br />contractual commitments. Public power s}-stems look for policies that <br />respect long-term contractual arrangements and keep the cost of capital <br />low by reducing the risk incurred as a result of such commitments. <br />This "stick to the basics" business model has served public power and its <br />customers well during the past few years, as was ver}~ apparent during the <br />California energry crisis. Public power entities in California and throughout <br />the country avoided making business decisions like those that triggered <br />the credit deterioration and ratings downgrades affecting the independent <br />power sector and many IOUs.2 Ironically, those public power <br />PubIIC pOWer entltl6S utilities that have suffered the most financially in recent }'Fars <br />COntlOUe t0 belleVe tha# got caught up in regional market blow-ups not of their making, <br />their Way Of Serving the or entered into transactions with counterparties that later <br />proved to be bad credit risks, unscrupulous, or both, <br />public works well. Federal <br />necessitating in some cases painful rate increases.3 <br />policies should. support <br />their ability tOCOntlnue t0 ~ Pt.rblic power entities continue to believe that their way of <br />_prOYlde SUCK SerVICe. serving the public works well. Federal poticies should support <br />their ability to continue to provide such service. By reorienting <br />FERC's policies to support long-term planning and investmf°nt in u~ansmission <br />and generation facilities, public power systems can continue to pro~'ide the <br />high-qualit}' electric ser-~~~ce that our consumer-owners have come to expect. <br />~ See, e. g., "Public finance Report Card: Public Power," Standard & Poor's, <br />published September 13, 2004, at 1 ("Since our last report card, published <br />Jan. 2], 2004, the sector has continued to experience overall credit stability, <br />and even slight improvement, with 10 upgrades and t~~o do~ti~ngrades. This is <br />in contrast with the experience of the investor-owned and merchant sectors, <br />which, despite seeing a moderation in the pace and severity of downgrades, <br />have 40% ~~f ratings carrying negati~t~ outlooks.").According to Standard <br />Poor's, only Live out of 246 public power s}'stems rated were below im-esrrnent <br />grade (and of these, four were California irrigation districts holding contracts <br />with Pacific Gas and Electric Company). Id. <br />~~ See, e.g. "Assessing Wholesale 1\larket Risk in Pacific Northwest Public Power <br />Ratings," Standard & Poor's, pi.iblished august 26, 2004, at 1 ("... (The Pacific <br />Northwest contributed a significant fi~action of the public power rating <br />downgrades in these }'ears. The vast majority oC these actions can he traced <br />directly to the increased risks oC wholesale po~~~er markets that defined the <br />western U.S. power crisis."). <br />Restructuring at the Crossroads: FERC Electric Policy Reconsidered 5 <br />