To the Editor:
Bruce Radford’s December 2006 article, “An Inconvenient Fact,” provides a helpful critique of a fundamental element of open-access transmission reform, one of the most important rulemaking cases affecting electricity regulation at the Federal Energy Regulatory Commission (FERC). The possibility of requiring non-RTO utilities to offer efficient balancing and congestion management through a security constrained economic (re)dispatch service including third parties would indeed be a helpful albeit modest reform of current rules. It would remedy an obvious type of discrimination utilities still can use to prevent third parties from gaining comparable access to the nation’s transmission systems. Furthermore, it would provide incentives for other constructive reforms rather than creating arbitrary obstacles to transmission access. However, the discussion of these matters would benefit from clarification of a few simple points.