TESTIMONY BY

DAVID K. OWENS
SENIOR VICE PRESIDENT
THE EDISON ELECTRIC INSTITUTE

BEFORE THE COMMITTEE ON AGRICULTURE, NUTRITION AND FORESTRY UNITED STATES SENATE

JULY 8, 1997

Introduction

Mr. Chairman and Members of the Committee:

My name is David Owens, and I am senior vice president for finance, regulation and power supply policy at the Edison Electric Institute (EEI). EEI is the association of U.S. shareholder-owned electric utilities. A super-majority of EEI's members have established EEI's approach to electricity competition, though a few members disagree with elements of that approach.

EEI's member companies are owned by their millions of shareholders, who hold utility stocks either directly, or indirectly through mutual funds, pension funds, employer 401(k) plans and life insurance policies. The majority of our companies' shareholders are over the age of 65, or approaching retirement age, and depend upon utility dividends to contribute to their retirement income.

Shareholder-owned utilities are located in every state except Nebraska and are a strong presence in rural America. According to a 1992 analysis, almost 60 percent of the power sold to rural electric consumers comes from shareholder-owned utilities, and nearly four out of five electric consumers living in small towns get their power from shareholder-owned utilities. We have invested in rural areas--not only in the infrastructure necessary to provide electric service, but also in economic development to promote jobs and a higher standard of living for rural Americans.

Today's Changing Electricity Market

This country's electricity industry is experiencing dramatic, fundamental changes as electricity markets make the transition to competition. These changes will have a profound impact on every American consumer because our economy is driven by electricity and our personal well-being depends on it.

These changes reflect the belief that efficient competition can result in lower prices and more innovative services and products to consumers. We all want to "get competition right." This means ensuring that affordable electricity is available for all consumers at all times. And, we want to make sure that our electricity infrastructure continues to operate reliably and safely for all consumers. We also want to ensure that all electricity competitors play by the same rules so that consumers choose the most efficient suppliers and competition is not distorted by federal exemptions, preferences, subsidies, uneven taxation and different levels of regulation.

In order to understand where the electricity industry is heading, it's important to understand where we are now. I'd like to share with you a few significant points.

First, real electricity prices in this country are 27 percent lower than they were fifteen years ago, and they are on a downward trend (see graphic, "Real Electricity Prices in the U.S."). U.S. industrial companies enjoy lower electricity prices than their competitors in other industrialized countries (see graphic, "Worldwide Industrial Electric Prices"). U.S. industrial electricity costs are about half that in Germany and a fourth of Japan's. In fact, industrial electricity prices over the past decade have declined in only one country: the United States.

Second, shareholder-owned utilities are heavily regulated at both the federal and state levels. The federal government regulates the wholesale electricity market. Sales of electricity by shareholder-owned utilities, as well as the price charged to move that electricity over shareholder-owned utilities' transmission lines, are regulated by the Federal Energy Regulatory Commission (FERC). The states traditionally have regulated electricity prices and services provided by shareholder-owned utilities to retail consumers. Retail electric service has been a state concern because the needs and priorities of electric consumers are directly affected by state differences such as economics, public policies, climate, population and geography.

Just last year, FERC issued an order requiring shareholder-owned utilities to open up their transmission lines to all participants in the wholesale market. This means that any wholesale power supplier can use transmission lines owned by shareholder-owned utilities at the same price, terms and conditions that those utilities charge themselves. FERC estimates that these competitive changes will result in annual savings of $3.8 billion to $5.4 billion to consumers. Unfortunately, FERC does not have the authority to apply this order to transmission lines owned by electric cooperatives, public power systems and the Power Marketing Administrations.

FERC's initiatives to spur competition in wholesale electricity markets have accelerated another significant trend in the industry: the growing number of electricity suppliers. There are literally thousands of electricity suppliers today (see graphic, "Suppliers Compete in Today's Power Markets"). There are more than 4,000 non-utility generation projects that generally sell their power to utilities. In the last five years, almost 60 percent of new generation came from these non-utility generators. Power marketers and brokers were almost non-existent three years ago, but have experienced explosive growth since then (see graphic, "Power Marketers Sales for Resale"). For example, in the first quarter of 1994, they sold enough electricity to power the equivalent of roughly 430,000 homes; in the first quarter of 1997, they sold enough electricity to power the equivalent of 75 million homes. Among suppliers who sell power to ultimate consumers, there are almost 2,000 municipal electric utilities, more than 900 electric cooperatives, and roughly 200 shareholder-owned utilities.

Just as FERC's actions have injected more competition into wholesale markets, the states are increasingly active in restructuring retail electric service (see map, "State Activities on Restructuring and Competition"). All fifty states are considering reforms to retail electric service. Those with the highest electricity prices, including California, Pennsylvania and the New England region, are pursuing the most aggressive reforms, although two lower cost states--Oklahoma and Montana--have also adopted retail competition plans (see map, "Average Cost per Kilowatthour--Total Industry, 1996").

Currently fourteen states, either through their state legislature or regulatory commission, have endorsed retail competition by a certain date. A number of states are experimenting with customer choice pilot programs to gain experience in establishing a new competitive market. Most states with average or lower-than-average electricity prices are moving more cautiously.

Under many of the state retail competition plans, electric cooperatives and municipal utilities are treated differently from shareholder-owned utilities. For example, in Montana, electric cooperatives are able to exempt themselves from the plan if they agree not to use other utilities' distribution systems to serve consumers. In Pennsylvania, electric cooperatives are exempted from the pilot program, although if they decide to compete outside their service areas they must provide reciprocal services to other suppliers. In Maine, electric cooperatives and municipal utilities are essentially "fenced in" to their service areas.

Essential Issues in the Transition to Competition

It is important to understand that power generation is the part of the industry that is becoming increasingly competitive, while the wires will remain a regulated monopoly. The utility that distributes power to homes and businesses in its service area today will perform the same function in a competitive market. States will still regulate the distribution wires, and FERC will still regulate the high-voltage wires over which power is transmitted.

However, even though the wires will remain regulated in a competitive market, we need to appreciate that the system is being used in a way different from its original design. For the most part, the current utility transmission and distribution lines were designed and built to move power short distances, from a local power plant to homes, offices, farms and businesses.

With hundreds of new participants using the wires, and as a result of FERC's open access rules, substantially new challenges are presented to preserve the reliability of the current system. Recognizing that these challenges will not simply take care of themselves, transmission owners and users are working to develop new institutions and "rules of the road" to ensure a continued high level of reliability.

The real question is, how do we increase competition in a way that benefits all consumers, protects the reliability of electric service and ensures that all electricity suppliers compete under the same rules? Making the transition to competitive electricity markets raises many complex and controversial issues--for both states and the federal government. Achieving our goals will take a balanced approach that recognizes the important role the states and federal government play in ensuring the nation's electricity supply. As part of the transition, certain issues that will affect all types of suppliers must be addressed.

Public Policy Programs

Over the past decades, electric utilities have served as an important vehicle in carrying out public policy programs and goals, such as universal service, low-income assistance and environmental programs. In competitive markets, with increased emphasis on price, there must be assurance that these programs are adequately funded and that all consumers help pay for these costs. Traditional utilities cannot be asked to bear the costs of these programs alone while other suppliers are not bound by these obligations.

In competitive markets, states must have adequate authority to regulate service providers to ensure that all consumers receive safe and reliable service, including the assurance of universal service to consumers who may be more costly to serve, such as those living in more remote, rural areas. In situations where consumers are likely to have fewer choices, or choose not to choose, states are considering options such as the availability of a "standard offer" so all consumers are assured they will have an electricity supplier. In assuring such consumer protections, consistent rules must be applied to all suppliers.

The state retail wheeling pilot programs have highlighted another important public policy issue for competitive markets: consumer education. Small consumers in particular may need tremendous education in order to sort through, and take advantage of, the varying offers for power and other services that will be offered in a competitive market. Stranded Costs

Another issue that must be addressed is the recovery of legitimate, verifiable and non-mitigatable stranded costs during a reasonable transition period. These are the costs which were incurred to meet utility obligations in a regulated world and but for the transition to competition would have been collected in electric rates. While the magnitude of stranded costs depends on the actual price of electricity in competitive markets, some have estimated these costs to be around $200 billion. The stranded cost problem is shared among all types of utilities--shareholder-owned, cooperative and municipal systems. According to Resource Data International (RDI), which has done an analysis of potential stranded costs, all three types of utilities are represented among the systems most heavily burdened by stranded costs.

For decades, shareholder-owned utilities have been regulated at the state level through a "regulatory compact." In exchange for a franchised service territory, utilities have been required to ensure that there are sufficient generating plants and other infrastructure to serve all present and future customers in that service area at regulated rates.

State regulators play an influential and continuous role in shareholder-owned utility business decisions. In most states, before a utility can build a generating plant, it must justify the need to regulators. Prices charged by shareholder-owned utilities are strictly limited by state regulators, who determine whether costs are reasonable before allowing utilities to recover them. And, regulators often require utilities to stretch recovery of approved costs over long periods of time--up to 30 years.

The costs that utilities have incurred include investments in power plants and long-term contracts for fuel or power. They also include costs under mandatory purchase obligations required by the Public Utility Regulatory Policies Act (PURPA). Many of these mandatory power purchase contracts are now at above-market prices. Costs have been incurred to fulfill other public priorities, such as low-income assistance, energy conservation, alternative fuel use and environmental programs. All of these costs, including others such as taxes and utility contributions to employee retirement plans, have the potential to become stranded in a competitive market.

These potential stranded costs will be paid by someone. There is no free lunch. The choices are departing consumers for whom the costs were incurred; the utility's remaining customers, who are likely to be the smaller consumers; or, in the case of our member companies, utility shareholders.

Some have asked why our shareholders should not pay for utility investment decisions. Let me respond. First, these costs were incurred with the approval or concurrence of regulators. Government must honor its past commitments. Second, regulators have already disallowed those costs that they determined to be unreasonable or imprudent. These disallowed costs are not part of the potential stranded costs and have already been absorbed by shareholders.

Third, shareholder-owned utilities operate under a different risk/reward system from other businesses. Utilities and their shareholders generally have traded the opportunity for higher financial returns for greater certainty of cost recovery through the regulatory process. Utilities were not allowed to earn returns commensurate with shareholders assuming the responsibility for stranded costs.

Fourth, it may take regulated utilities 30 to 40 years to recover capital invested through regulated rates. This practice results in lower rates in early years. It is inappropriate to disallow recovery in mid-stream, when consumers have already benefitted from these lower rates.

We also need to look at who utility shareholders are. As I mentioned earlier, millions of Americans own utility shares, either directly, or indirectly through investment vehicles such as pension funds and 401(k) plans. In a recent listing of the 50 most widely held stocks, ten were shareholder-owned utilities. The majority of our shareholders are at or near retirement age and have held onto their utility stocks for more than nine years. Our shareholders buy utility stocks so they can use the dividends to supplement their retirement income. Their investment should not be devalued or lost because public policy makers are changing the rules of the game.

Both federal regulators and most state governments have recognized the importance of assuring stranded cost recovery. In its open access rule, Order No. 888, FERC took the position that utilities would be allowed the opportunity to seek to recover their legitimate and verifiable stranded costs resulting from wholesale competition. As FERC stated, requiring open access transmission "carries with it the regulatory public interest responsibility to address the difficult transition issues...[t]he most critical transition issue...is how to deal with the uneconomic sunk costs that utilities prudently incurred under an industry regime that rested on a regulatory framework and a set of expectations that are being fundamentally altered." Stranded cost recovery was also affirmed in both the 1996 and 1997 Economic Reports of the President. States that have approved retail competition plans have also included provision for stranded cost recovery.

State Tax Issues

States must also consider the tax and revenue implications of electricity restructuring on their state economies. State and local taxes imposed on shareholder-owned utilities include gross receipts taxes, income taxes, property taxes and franchise fees. In addition, utilities frequently act as tax collectors for government, collecting sales and use taxes and utility user taxes. In 1994, shareholder-owned utilities paid more than $13.4 billion in various state and local taxes.

Electricity competition raises significant tax issues for state and local governments. In a number of states, utility-based taxes serve as the major source of revenue for school districts. In communities where their generating facilities are located, utilities typically are the largest taxpayer, with those communities relying on utility property taxes to help build roads and schools and provide community services.

According to a Deloitte & Touche study, competition is likely to cause government revenues to decline as a result of "lower electricity prices, a shift in market share from more to less heavily taxed providers and declining values of property owned by utilities." In many states, electricity suppliers are taxed differently. For example, property owned by a shareholder-owned utility frequently is taxed at a higher rate than identical property owned by another type of electricity supplier.

Federal Electricity Issues

Because of the unique circumstances in each state, it is entirely appropriate for the states to take the lead in the timing and method of reforms to retail electric service. However, there are electricity issues that only Congress can address. Many federal statutes unfairly handicap certain electricity suppliers before they even leave the starting gate. The problems created by these federal statutes will only be magnified and exacerbated as more states endorse retail competition.

Our principle is a simple, fundamental one: in competitive markets, the same rules should apply to all suppliers. This is essential for the most efficient, innovative and responsive companies to succeed. The current unequal treatment of suppliers has been problematic under a regulated system where utilities have defined service areas; such treatment will have dramatic, unintended economic consequences when utilities and other suppliers go head to head to compete for the business of retail consumers.

The electric utility industry is strikingly different from other deregulated industries in this respect: private enterprise does not have to compete with government-owned or subsidized providers in the natural gas business, the airline industry or the banking industry, for example. In the electric utility industry, however, roughly one-quarter of the nation's consumers receive electric service from electric cooperatives and public power systems. Electric cooperatives and public power systems are regulated to a much lesser degree than shareholder-owned utilities; they also are taxed very differently at the federal, state and local levels. In addition, their capital financing methods are significantly more advantageous than shareholder-owned utilities.

While not a comprehensive list of issues that Congress needs to examine as electricity restructuring moves forward, I want to highlight the following concerns.

Tax and Financing Issues

In 1995, shareholder-owned utilities paid almost $26 billion in taxes. Of this amount, roughly $12 billion was paid to the federal government and almost $14 billion was paid to state and local governments. As a percentage of operating revenues, shareholder-owned utilities pay roughly twice as much in taxes as electric cooperatives and municipal utilities pay in taxes or payments in lieu of taxes. Shareholder-owned utilities are generally covered by the same Internal Revenue Code provisions as other tax-paying businesses while paying one of the highest effective rates (approximately 25 percent) of any U.S. industry.

Electric cooperatives are exempt from most federal taxes, except Social Security; they also are exempt from most state and local taxes. Public power systems are exempt from federal and state income taxes, as well as other taxes such as property, gross receipts and excise taxes. While shareholder-owned utilities receive certain tax benefits, this does not equate to the 100% tax exemption for municipal utilities and electric cooperatives.

Because generation, distribution and transmission functions are all highly capital intensive, utilities are very sensitive to the availability and cost of capital. The cost of capital in this industry is higher than in virtually any other industry. While shareholder-owned utilities raise their financing in private capital markets, electric cooperatives are eligible for direct federal loans and loan guarantees that provide below-market interest rates. Public power systems have the ability to issue tax-exempt securities, which carry a lower interest rate. Also, both electric cooperatives and public power systems can be 100 percent debt financed, resulting in a lower cost of capital. In addition, electric cooperatives and public power systems determine themselves how to allocate costs within their capital structure while shareholder-owned utilities are controlled by regulatory authorities.

When different types of electricity suppliers compete for customers, these disparate tax and financing treatments will distort the marketplace. Applying our general "same rules" principle, when electric cooperatives and public power systems compete for customers outside their traditional service areas, they should do so under the same tax rules that apply to shareholder-owned utilities.

USDA Rural Electric and Rural Development Programs

The U.S. Department of Agriculture (USDA) administers a wide range of loan and grant programs designed to promote rural economic development and job creation. We believe that all rural Americans should have access to these federal rural development funds. However, this is not the case. Under current law, electric cooperatives are eligible to serve as a primary delivery mechanism for these funds while shareholder-owned utilities are not. As a result, federal rural development assistance can easily flow into rural areas served by electric cooperatives, but not into rural areas served by shareholder-owned utilities.

If the purpose of these programs is to provide federal assistance to promote jobs and economic development in rural areas, then all rural areas should have access to those funds. Access to federal assistance should not be biased or cut off based simply on who owns the electric distribution wires serving that rural area.

Electric Cooperative Loan Writedowns

A number of electric cooperatives--especially power supply cooperatives--are experiencing financial difficulties and asking the Rural Utilities Service (RUS) for loan forgiveness in the form of write-downs and write-offs. Almost $1.5 billion, involving just two cooperatives, has already been forgiven.

The RUS has loaned roughly $33 billion to electric cooperatives. About $24 billion of this amount is owed by power supply cooperatives, which generate electricity. A recent General Accounting Office (GAO) study found that 12 power supply cooperatives, representing 25 percent of the outstanding loans in dollars (but only two percent of the borrowers), are at or near default on over $8 billion in outstanding principal.

Of particular concern is the recent effort of the electric cooperatives in the Senate Finance Committee to eliminate entirely the current-law provision that requires electric cooperatives to receive 85 percent or more of their revenues from sales to their members. Under current law, a bailout of an existing debt to an electric cooperative (or any other group) is considered income to that organization. Thus, the larger the bailout at taxpayer expense, the more likely it is that the 85 percent rule could be violated. Elimination of this rule would open the floodgates to taxpayer-financed bailouts of existing debt for electric cooperatives.

Until 1993, all RUS write-downs and write-offs needed concurrence of the Office of Management and Budget (OMB) and the Department of Justice (DOJ) in order to help protect the U.S. government and taxpayers. OMB was dropped from the process in 1993. Last year's farm bill removed DOJ from the process as well and relieved the RUS of virtually all reporting requirements.

We believe that American taxpayers should be concerned about the decrease in the program's supervision as well as the relief of the reporting requirements, which are the only means Congress and the public have for monitoring the program's management. America's taxpayers deserve better than a program operating with virtually no controls and little if any accountability. Because the RUS has been relieved of important reporting requirements, we do not know which cooperatives are in trouble or even how many. We do not know how many or which cooperatives have sought relief or which cooperatives and how many are currently in negotiation. Neither Congress nor American taxpayers will know any of this until they read in the newspapers that another round of bailouts is a fait accompli.

Federal Disaster Assistance Programs

The recent devastating floods in North Dakota and Minnesota again focused attention on the importance of federal disaster assistance in helping communities to clean up and rebuild. Unfortunately, while electric cooperatives and municipal utilities are eligible to receive disaster assistance from the Federal Emergency Management Agency (FEMA), shareholder-owned utilities are not.

Every time a natural disaster occurs--whether it's a hurricane in the Southeast or an earthquake in California or an ice storm in Pennsylvania--electric consumers are painfully reminded of how this disparate treatment affects them. In devastated areas, consumers literally living on different sides of the road can be divided into "haves" and "have-nots" when it comes to the availability of federal disaster assistance to rebuild their electric systems. Unfortunately, a hurricane or flood or tornado doesn't make such a distinction. Again, if the purpose of federal disaster assistance to electricity suppliers is to help people rebuild their lives, businesses and communities, then shareholder-owned utilities should not be excluded from assistance.

FERC's Open Access Rules

As I mentioned earlier, FERC's open access rules require shareholder-owned utilities to open up their transmission systems to other electricity suppliers. Unfortunately, these open-access requirements apply only to shareholder-owned utilities and not to a significant number of other transmission-owning utilities, such as electric cooperatives, the federal Power Marketing Administrations (PMAs) and public power systems, which are not fully subject to FERC's jurisdiction (see map, "Not All Power Suppliers Subject to FERC Jurisdiction").

As a result, one-quarter of the country's transmission system, which is controlled by these suppliers, is not fully open for the benefits of wholesale competition. This roadblock to full open access can be a major problem in parts of the country where non-jurisdictional utilities own large portions of the transmission network. For example, Bonneville Power Administration owns and operates roughly 80 percent of the bulk power transmission in the Northwest. But, it does not have to play by the same open-access rules as the surrounding shareholder-owned utilities in that region.

It is ironic that, after being vigorous proponents of open access to shareholder-owned utilities' transmission systems, electric cooperatives and public power systems are refusing to play by the same rules. So far, only ten public power system and electric cooperatives have voluntarily filed an open access tariff with FERC. EEI's member companies believe that vigorous wholesale competition requires that full open access to all transmission systems be available to all electricity providers. Open access will not achieve its full potential benefits for consumers unless all transmission owners are full participants in the system. FERC should be granted the authority to impose the same requirements on electric cooperatives and public power systems as it currently imposes on shareholder-owned utilities.

Preference Power

Both electric cooperatives and public power systems enjoy preferential access to mostly low-cost hydropower generated at federal facilities and marketed through the PMAs. Shareholder-owned utilities generally are not eligible for firm priority power sales from the PMAs.

The Bonneville Power Administration (BPA) recently received permission to sell excess federal power outside its traditional marketing area. As a result, BPA is planning to compete head-to-head with other suppliers in California when that state's retail market is open to competition in January 1998.

It is grossly unfair to private-sector energy suppliers to expect them to compete with a federal power agency that pays no taxes, is sheltered from numerous regulatory programs and borrows its investment capital from the government. More important, it is unfair to taxpayers to market this power under a scheme that may not return fair market value to the taxpayers.

When the federal government sells resources such as coal, natural gas, oil and timber, they do so under statutes which are designed to ensure that taxpayer interests are maximized. No such statute governs the sale of excess power from BPA. There are no minimum bid procedures, no determination of "fair market value," no post-sale audit or judicial review--all of which are required when the federal government sells anything else of value.

The role of the PMAs and preference power in a competitive electricity market needs to be examined. At one time, electric cooperatives and municipal utilities may have used preference power as part of a competitive "benchmark" for the industry. However, in highly competitive wholesale markets with open transmission access, it is easy to match buyers with eager sellers of affordable electricity. If the role of PMA power is to ensure that rural areas and small towns receive affordable power, then all electricity suppliers who serve those consumers should be eligible to buy PMA power, not just some.

Public Utility Regulatory Policies Act (PURPA)

The mandatory purchase obligation under PURPA has forced utilities to purchase power at above-market prices even when they don't need it. These mandated purchases are estimated to exceed today's market prices by more than $38 billion. This policy is outdated in an increasingly competitive marketplace, exacerbates a utility's potential stranded costs and should be repealed prospectively. The mandatory purchase obligation also is anti-consumer, forcing them to pay at least $38 billion in above-market prices due to existing PURPA contracts.

Public Utility Holding Company Act of 1935 (PUHCA) PUHCA imposes an additional layer of regulation and restrictions on 14 registered electric and gas holding companies. PUHCA gives the Securities and Exchange Commission (SEC) extensive authority to regulate holding companies' capital and corporate structure. PUHCA prevents these companies from responding quickly to consumers' needs and from offering their consumers the range of services and products that are likely to exist in competitive markets. PUHCA also will limit consumers' choices of electricity suppliers by hindering the ability of certain suppliers to operate in different states.

Since 1935, federal and state regulation of holding companies and electric utilities in general has expanded greatly and has evolved into much closer oversight of utility activities at both the state and federal levels. The Act's consumer and investor protections are duplicated in other federal and state laws. PUHCA should be repealed and certain consumer safeguard responsibilities transferred to FERC and the states, as recommended by the SEC and approved recently by the Senate Banking Committee in S. 621.

Conclusion

Electricity markets are changing dramatically as they become increasingly competitive. While experiences with other deregulated industries can give us some inkling of what to expect, we simply do not have all the answers because electricity is unique. We do expect many new players competing in electricity markets, so consumers may see familiar brand names in an unfamiliar market, offering to sell them electricity. And, it is possible that consumers will be able to purchase electricity, natural gas, telephone service, cable television and home security through one supplier.

While consumers generally like choice, many are apprehensive about change. Whether they are a farmer living in a very rural area or a suburbanite or an inner-city resident, they are concerned about the same things: they want to have the same variety of choices as other consumers do, they do not want to end up paying more for a service they regard as essential, and they want reliable electric service they can depend on. And, they want to know who to call when they do not get what they want.

The electric utility industry is a $200 billion a year industry, and it is the country's most capital intensive industry. Electricity powers our economy; it not only is essential to our well-being, it improves the quality of life of every American consumer. Clearly, as our industry makes the transition to more competitive markets, there are many issues raised, questions to be answered and decisions to be made that will affect every American. That's why we emphasize that it's important that we "get it right." America's consumers cannot afford for the transition to competition to be done wrong.

The states are making progress in addressing the issues, answering the questions and making the decisions on restructuring retail electric service. However, it is clear that the federal government has an important role. Just because we do not support a federally mandated date certain for retail competition does not mean that we believe Congress should not consider any electricity legislation. As I outlined in my statement, there are issues that only Congress can address, and more are likely to become clear as the states make progress on restructuring.

We want to make sure that American consumers enjoy reliable and affordable electricity. We want to make sure that electricity suppliers play by the same rules in competitive markets to ensure that the most efficient and innovative are successful. We all want to "get it right." We look forward to working with you to achieve these goals.