The Pennsylvania Public Utility Commission has taken new steps in its ongoing effort to restructure the state's electric industry, proposing regulations to govern customer choice of energy suppliers and securitization of stranded costs.

The PUC's new actions on retail choice and stranded costs were designed to comply with state legislation passed last December, known as the Electricity Generation Customer Choice and Competition Act. See, 66 Pa.C.S. secs. 2801 et seq.

In fact, the PUC began last January to implement the new state legislation.

Today's critics decry stranded costs, yet fail to cover their tracks.

Many of today's most vociferous critics of stranded cost recovery were once among the most ardent supporters of the nuclear plants they now disavow.

Back in the '70s, when electric utilities and regulators laid out their long-term plans, nuclear power played a leading role, and American industry largely concurred. Now, however, 20 years later, the business sector sings a new tune. "I told you so," the refrain goes.

"When they come to town ... we'll ... accompany them to Capitol Hill ... to make their trip to Washington a 'two-fer,' if you will."

Paul Rodgers knocked NARUC on its ear last July when he announced his resignation as executive of that century-old association.

Rodgers, also general counsel, had served the National Association of Regulatory Utility Commissioners for more than 30 years.

His unexpected move came in the midst of strategic planning at NARUC.

When viewed as serving market segments, utilities differ little from manufacturing companies, where most costs are shared among products and processes.

Activity-based cost management has had a tremendous impact on manufacturing enterprises; and its use has spread to some service industries such as banking, insurance and health care. ABCM encompasses two well-known management concepts: activity-based costing and activity-based management. Now that electric utilities are gearing up for competition, it is time to ask if ABCM has any relevance in the public utility industry.

Mr. Lindsay's March 1 letter (PUBLIC UTILITIES FORTNIGHTLY, p. 6) requires some further discussion. We do agree that reducing cooling seasonal peak electric demand is desirable. Lessening the electric infrastructure's environmental effects and electric system failures, as we witnessed in the summer of 1996, is to the public good. However, thermal storage systems have siting issues and the potential to run out of capacity at the worst possible time on peak days.

I was surprised and disappointed at the limited and unbalanced perspective that Bruce Radford brought to his comments on securitization ("Wall Street's New Game," PUBLIC UTILITIES FORTNIGHTLY, April 15, 1997, p. 4).

The article implies that the push for securitization legislation is being driven by the investment community's desire to create an investment product with a guaranteed return.

I read with interest your editorial regarding securitization in the April 15 edition of PUBLIC UTILITIES FORTNIGHTLY. As the chairman of the New York State Standing Committee on Energy & Telecommunications, I must take issue with your inclusion of statements from opponents to such legislation without providing its sponsors with the opportunity to press their case.

The Senate, on March 19, 1997, passed legislation that I sponsored at the request of Gov. George E.

While the prices play catch up, utilities and regulators should start looking for ways to mitigate costs.

Water utility rate increases have outpaced those of other utilities. In fact, water rate increases since 1984 %n1%n have surpassed the overall rate of inflation. Yet among utility services, water remains a real bargain; consumers spend less on water than on any other utility.

New England states, feeling threatened by increased pollution from Midwest coal-fired generation, recently began lobbying for tougher national environmental standards tied to electric deregulation legislation. The perceived threat is based on the belief that coal-fired plants in the Midwest with excess capacity will increase exports to higher-cost New England states. This increased generation and exportation could lead to more pollution in the New England states.

Changing the culture at American Electric Power.

As the electric industry gears up for competition, attention shifts to things like load migration, technology and customer service. The pressure is rising like never before to identify, catalogue and track costs.

Thus, at American Electric Power Company, we decided two years ago to reengineer much of our internal financial management apparatus, including systems, databases and technology. With the help of consultants, we developed, designed, tested and implemented an activity-based management system.