Energy Markets: Results of Studies Assessing High Electricity	 
Prices in California (29-JUN-01, GAO-01-857).			 
								 
Wholesale electricity prices in California rose sharply in May	 
2000 and have remained high. In addition, there were disruptions 
in service--blackouts--this winter and spring. The California	 
Independent System Operator, the state agency in charge of	 
balancing electricity supply with demand, expects high prices and
service disruptions to continue and perhaps worsen this summer.  
In response to concerns about high prices and generator outages  
in California, the Federal Energy Regulatory Commission (FERC)	 
undertook a study, released in February 2001, to determine	 
whether outages were being used to withhold power and drive up	 
prices of electricity in California. Other studies of the	 
electricity market in California have been conducted by 	 
economists and industry experts. One study, conducted by three	 
economists from Stanford University, the University of California
at Berkeley, and the University of California Energy Institute	 
examined whether market prices of electricity in California in	 
1998 and 1999 were higher than competitive levels. A second,	 
similar study by two economists--one from the Massachusetts	 
Institute of Technology and one from a private consulting	 
firm--examined the California market during 2000. This report	 
reviews the FERC study, as well as the two studies on the	 
California electricity market to determine (1) how the		 
methodologies and results of the three studies compare and (2) if
FERC's study was thorough enough to support its conclusions that 
audited companies did not physically withhold electricity	 
supplies to influence prices. GAO found that FERC's study used a 
very different methodological approach from the approach used by 
the other two studies and reached different conclusions. FERC's  
study performed an audit of specific generating plants and	 
companies that experienced outages to determine if audited	 
companies were incurring outages in an effort to drive up prices,
while the other two studies compared market prices with estimates
of the costs of producing electricity. GAO further found that	 
FERC's study was not thorough enough to support its conclusion	 
that audited companies were not withholding electricity supply to
influence prices.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-857 					        
    ACCNO:   A01247						        
  TITLE:     Energy Markets: Results of Studies Assessing High	      
             Electricity Prices in California                                 
     DATE:   06/29/2001 
  SUBJECT:   Comparative analysis				 
	     Electric energy					 
	     Electric utilities 				 
	     Energy costs					 
	     Energy shortages					 
	     Prices and pricing 				 
	     Statistical methods				 
	     California 					 

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GAO-01-857
     
Report to Congressional Requesters

United States General Accounting Office

GAO

June 2001 ENERGY MARKETS Results of Studies Assessing High Electricity
Prices in California

GAO- 01- 857

Page 1 GAO- 01- 857 FERC Study of Electricity Outages

June 29, 2001 The Honorable Jay Inslee The Honorable Peter A. DeFazio House
of Representatives

Wholesale electricity prices in California rose sharply in May 2000 and have
remained high. In addition, there were disruptions in service- blackouts-
this winter and spring. The California Independent System Operator, the
state agency in charge of balancing electricity supply with demand, expects
high prices and service disruptions to continue and perhaps worsen this
summer. Some other western states, including Oregon and Washington, have
also experienced increases in their wholesale electricity prices since the
summer of 2000.

A number of factors have likely contributed to these high wholesale
electricity prices and service disruptions, including rapid demand growth
since 1995 accompanied by slow growth in supply, higher- than- normal
natural gas prices, and flaws in the design and structure of California?s
electricity market. In addition to these factors, state officials and others
have attributed the problems, at least in part, to market power, exercised
by individual electricity- generating companies. Some have argued that
generating companies have staged outages of generating units to reduce
supply and drive up prices. As evidence, they point to a higher- than-
normal level of such outages since the summer of 2000.

In response to concerns about high prices and generator outages in
California, the Federal Energy Regulatory Commission (FERC) undertook a
study, released in February 2001, to determine whether outages were being
used to physically withhold power and drive up prices of electricity in
California. Other studies of the electricity market in California have been
conducted by economists and industry experts. One study, conducted by three
economists from Stanford University, the University of California at
Berkeley, and the University of California Energy Institute examined whether
market prices of electricity in California in 1998 and 1999 were higher than
competitive levels. A second, similar study by two economists- one from the
Massachusetts Institute of Technology and one from a private consulting
firm- examined the California market during 2000.

Concerned about the potential use of market power to drive up electricity
prices, you asked us to evaluate the FERC study, as well as the two studies

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 01- 857 FERC Study of Electricity Outages

on the California electricity market. 1 As agreed with your offices, this
report addresses two questions: (1) How do the methodologies and results of
the three studies compare? (2) Was FERC?s study thorough enough to support
its conclusions?

FERC?s study used a very different methodological approach from the approach
used by the other two studies and reached different conclusions. FERC used a
case- study methodology analyzing a number of specific generating plant
outages to determine whether they were used strategically by generating
companies to push up prices of electricity or whether they resulted from
unavoidable or routine repairs or maintenance. As part of this methodology,
FERC conducted telephone interviews with generating companies to verify the
reasons for outages. It also visited the headquarters of two companies and
performed on- site inspections at three generator plant sites. In every
case, FERC found that legitimate repairs or maintenance was performed on the
downed generating plants and on this basis, found that there was no evidence
these companies were using outages strategically to withhold power and
influence prices. However, FERC pointed out that its report did not analyze
whether companies were using other techniques to influence prices, such as
not offering bids to sell capacity at certain times, or bidding at prices
high enough to practically ensure that their supply would be excluded from
the market. The other two studies looked for evidence of the existence and
exercise of market power in the entire market, rather than focusing on
particular instances of generator outages. They compared wholesale market
prices with the costs to generate electricity to determine if prices were
significantly higher than would be expected if generators were acting
competitively. The authors of both studies concluded that prices were higher
than competitive levels, strongly suggesting that market power has been used
in California to increase prices of electricity.

FERC?s study was not thorough enough to support its overall conclusion that
audited companies were not physically withholding electricity supply to
influence prices. FERC?s study was largely focused on determining whether or
not there were actual physical problems- such as leaks in cooling tubes- in
generating plants experiencing outages. However, industry experts we spoke
with generally agree that it is practically impossible to accurately
determine whether such physical outages are

1 See appendix I for bibliographic information about the studies. Results in
Brief

Page 3 GAO- 01- 857 FERC Study of Electricity Outages

legitimate or not because plants frequently run with physical problems, and
the timing of maintenance or repairs is often a judgment call on the part of
plant owners or operators. In discussions with FERC, officials acknowledged
that simply looking at outages and maintenance records of generators is not
sufficient to determine whether generating companies are exercising market
power to increase prices. A thorough study of market power would combine the
market- wide approach of the other two studies with a quantification of the
extent to which outages, or other supply disruptions, were caused by factors
other than companies? attempts to drive up prices. Because the other two
studies did not evaluate all the factors that could have led to an
abnormally high level of generator outages, their results are not conclusive
with regard to the precise extent that market power caused the observed high
prices. To improve on its market monitoring, FERC officials told us that the
agency has recently implemented a more comprehensive plan for detecting the
exercise of market power.

We provided the Chairman of FERC with a draft of this report for review and
comment. FERC agreed with the basic findings in the report but took issue
with our characterization of its conclusion, saying that FERC had only
concluded the absence of evidence of withholding electric power, rather than
the absence of withholding to influence prices. In addition, FERC pointed
out that it is important to make a distinction between its study, which
focused on engineering reasons for outages, and the other two studies, which
focused on economic reasons for withholding electric power.

California moved to a deregulated electricity market in April 1998. For
roughly 2 years, wholesale prices were fairly low on average. However, the
state experienced periods of higher prices, especially during peak summer
hours. Average prices rose dramatically in May 2000 and remained high. For
example, average prices of electricity sold in the California Power Exchange
during the months of May through December 2000 were between 2 and 13 times
higher than in the same months of the previous year. In addition to higher
prices, the frequency and duration of periods when the system is in danger
of service disruptions have increased. Actual rolling blackouts occurred on
6 separate days in winter and spring 2001, for a total of 16 hours with
shortfalls ranging from 400 to 1,000 MW. Blackouts adversely affected
consumers and caused business and traffic disruptions.

The California electricity market operates within a larger western system
consisting roughly of 11 states, and while California relies on imports for
Background

Page 4 GAO- 01- 857 FERC Study of Electricity Outages

about 20 percent of its supplies, it also exports power at times to other
states. As a result of this interconnectedness, the price and availability
of power in California influence markets in other western states and vice
versa.

Industry experts and academics generally agree that a tight power supply in
California and other western states is one reason why prices increased and
service reliability deteriorated starting in May 2000. The demand for
electricity in California has grown rapidly since 1995, while very little
new generating capacity has been added. For example, from 1995 through 2000,
total electricity consumption grew by about 13 percent, compared with about
2- percent growth in electricity generating capacity in the state. In
addition, last summer saw an increase in the price of natural gas- used to
produce about 40 percent of California?s electricity supply- and in the
price of emissions permits that are required to operate certain generators
in California. Lower levels of available hydroelectricity during summer 2000
in the Pacific Northwest reduced California?s access to imports of
hydroelectricity. Rapid demand growth in other states has also reduced
California?s ability to import electricity from those states. Finally, flaws
in market design in California are widely believed to have contributed to
California?s problems. For example restrictions on the use of long- term
contracts to purchase electricity increased the reliance of California?s
three investor- owned utilities on spot markets and left them substantially
exposed to market risks.

While these factors contributed to California?s electricity problems, a
number of state officials, economists, and industry experts now believe that
the market design adopted by California has enabled individual electricity-
generating companies to exercise market power by withholding capacity when
supplies are tight in order to drive up prices. They argue that generating
firms have withheld supplies of electricity by staging outages in order to
drive up prices, and point to higher- than- normal levels of outages since
summer 2000.

FERC?s study differed from the other two in its methodological approach and
reached different conclusions. In addition, all three studies covered
different time periods, so their results are not entirely comparable. FERC
performed an audit of specific generating plants and companies that had
experienced outages during December 2000. On the basis of these audits, FERC
found that there was no evidence that the audited companies were incurring
physical outages in an effort to drive up prices. The other two studies
examined market prices and compared them with estimates of the costs of
producing electricity to determine if prices were consistent with Studies
Used

Differing Methodologies and Reached Different Conclusions

Page 5 GAO- 01- 857 FERC Study of Electricity Outages

generating companies? exercising market power. Both of these studies,
conducted during different time periods, concluded that there was evidence
of market power used to increase electricity prices.

FERC followed a case- study methodology, analyzing generating plant outages
to determine if generating companies used them strategically to push up
electricity prices or if they resulted from unavoidable or routine repairs
or maintenance. FERC analysts conducted telephone interviews with generating
companies to verify the reasons for outages. These telephone interviews
covered about 60 percent of the reported outages. In addition, they visited
the headquarters of two companies whose generating plants were down for
maintenance or repairs to discuss in more detail the companies? repair
policies, maintenance schedules, and operating practices. They also
performed on- site inspections of generators at three plant sites and
observed maintenance and repairs. In order to evaluate the legitimacy of the
repairs or maintenance being performed, FERC employed private- sector
consultants familiar with plant operations to accompany FERC analysts during
the on- site visits. In addition to the audits, FERC examined market prices,
levels of demand, and generator outages for the month of December 2000 to
determine whether high levels of outages were correlated with higher prices
of power.

Based on the results of its audits, FERC found that there was no evidence
that the audited generating companies were withholding power in an attempt
to influence prices. On the contrary, in every case, FERC found that
legitimate repairs or maintenance was performed on the downed generating
plants. Moreover, it found that these plants were typically older- 30 to 40
years old- and had been used more intensively than usual during the summer
and fall of 2000. In addition, FERC found that prices in the month of
December were not strongly correlated with levels of outages. In fact, it
found that the highest prices occurred during periods with relatively lower
levels of generator outages.

The other two studies looked for evidence of the existence and exercise of
market power in the entire market, rather than focusing on particular
instances of generator outages. They employed a methodology that compared
market prices with estimates of the marginal costs of producing additional
electricity. Marginal cost is the additional cost incurred to produce one
more unit of electricity. Prices close to the marginal cost are consistent
with a competitive market. High prices, however, may suggest that the market
is not competitive and that individual electricitygenerating companies can
manipulate prices. FERC?s February Review

of Outages Found No Evidence of Supply Withholding

Two Studies Comparing Costs and Prices Suggest That Market Power Exists

Page 6 GAO- 01- 857 FERC Study of Electricity Outages

The first study we examined, by Borenstein, Bushnell, and Wolak, compared
prices with estimated costs of producing electricity in the period from June
1998 through September 1999. The authors constructed the market supply of
electricity by estimating the cost of generating each additional unit of
electricity, starting with the lowest- cost generating plants and adding
increasingly costly plants. They used statistical simulation methods to take
account of random generator outages, which decrease the electricity supply
as units go off- line for repairs or maintenance and increase it as
generating plants come back on- line. By matching actual demand at any point
in time with their simulated supply of electricity, the authors were able to
estimate the competitive price of electricity- that is, the price equal to
the marginal cost incurred to supply the last unit of electricity demand.
Then they compared the estimated competitive price with the actual price.

Based on their analysis, Borenstein, Bushnell, and Wolak concluded that
there were periods of high prices and high demand from June1998 to September
1999, which they attribute to the exercise of market power. The authors
found that on average, the prices during this period were 16 percent higher
than they would have been had generators behaved competitively. In
discussion with one of the authors, we were told that while their study
provides strong evidence of market power, it does not suggest any illegal
activity on the part of electricity- generating companies. On the contrary,
he believes that individual companies are sometimes able to exercise
unilateral market power to raise prices without violating antitrust laws.
The authors did not examine outages to try to determine whether the level or
pattern was consistent with companies? withholding power, nor did they seek
to determine precisely how generating companies exercised market power. In
discussions with one of the authors, we were told that it is not possible to
tell the difference between an unavoidable outage and a strategic outage
designed simply to drive up prices. Moreover, a generating company might
exercise market power in other ways. For example, a company can simply
submit selling bids that are so high that all of its power will not be
purchased, thus effectively reducing the volume of electricity sold in the
market and causing prices to rise.

The second study, by Joskow and Kahn, examined electricity prices during
summer 2000. The authors conducted a similar study to that of Borenstein,
Bushnell, and Wolak, but their access to data was more limited. As a result,
Joskow and Kahn relied on publicly available data for some key variables
rather than the confidential and proprietary data used in the other study.
Their study also differed from the first in that Joskow and

Page 7 GAO- 01- 857 FERC Study of Electricity Outages

Kahn analyzed outages during June 2000 to determine the extent to which
withheld generating capacity was a factor in explaining high electricity
prices. In doing so, they compared the volume of electricity generated at
specific prices with their estimates of how much electricity could have been
produced profitably at those prices, taking into account normal levels of
unplanned outages and capacity held in reserve for system reliability
reasons.

Based on their analysis, Joskow and Kahn concluded that there was strong
evidence that market power was exercised to raise prices in summer 2000.
They found that higher prices of electricity were caused in part by higher
natural gas prices, increased demand, reduced availability of imports and
higher prices for air emissions permits. However, they also found that
prices in summer 2000 were greater than they would have been had the market
behaved competitively. In addition, they concluded that the level of outages
experienced during June 2000 cannot be explained by reasonable expectations
about repairs or maintenance requirements, or by the need to hold power in
reserve for system reliability reasons. However, the authors acknowledge
that data limitations make their analysis of withheld generating capacity
somewhat rough. Specifically, they lacked data on generating units outside
of but selling power in California and contractual arrangements by
electricity power marketers doing business in the state. Therefore, they
were unable to measure generator outages outside of California.

FERC?s study of electricity generator outages was not thorough enough to
support its overall conclusion that the audited companies did not physically
withhold electricity supplies to influence prices. FERC?s study was largely
focused on determining whether or not there were actual physical problems-
such as leaks in cooling tubes- in generating units experiencing outages.
Under this approach, if FERC found that there were physical problems with
downed generating plants and that repairs or maintenance were performed,
then it concluded that the outage was legitimate and not designed to simply
reduce supply and push up prices. In fact, FERC determined that most of one
company?s generating plants were old and suffered from mechanical problems.
In addition, FERC found that many of these plants had run at higher- than-
usual rates in the summer and fall of 2000, prior to their shutting down for
repairs or maintenance. These facts do suggest that a higher level of
outages than normal should be expected. However, the industry experts we
spoke with generally agree that it is practically impossible to accurately
determine whether such outages are legitimate or not because plants
frequently run with physical FERC?s Study Not

Thorough Enough to Support Its Conclusion

Page 8 GAO- 01- 857 FERC Study of Electricity Outages

problems, and the timing of maintenance or repairs is often a judgment call
on the part of plant owners or operators.

Another weakness in the FERC study- or any study that seeks to determine
whether specific outages are legitimate- is the lack of data for past
outages to use as a benchmark with which to compare the number, type, and
duration of outages during the study period. In discussions with FERC,
officials told us that accurate outage data do not exist for the years prior
to their study. 2 Without a baseline comparison, it is not possible to
conclude that observed outages are above normal in number, type, and
duration. Finally, strategic use of plant outages is not the only way that a
generating company could exercise market power, and FERC?s methodology did
not look at other ways. As FERC acknowledged in its report, the agency did
not analyze whether companies were using other techniques to influence
prices, such as not offering bids to sell some capacity, or bidding at
prices high enough to practically ensure exclusion from the market.

A thorough and conclusive study of market power in California since May 2000
would combine the market- wide approach of the other two studies, with a
quantification of the extent to which outages or other supply disruptions
were caused by factors other than companies? attempts to drive up prices. In
its study, FERC pointed out two such factors that could lead to higher-
than- normal levels of outages: (1) some plants had been run at above-
normal rates prior to being shut down for repairs or maintenance, and (2)
many plants that were shut down were older. A third factor, suggested by
other industry sources, is that a number of companies were simply refusing
to operate their generators at various times during 2000 because they had
not been paid for electricity they had previously sold to California?s
utilities. None of the studies covered the entire period of high prices, nor
did they evaluate all the factors that could have led to greaterthan- normal
levels of generator outages. Therefore, their results are inconclusive about
the precise extent to which market power versus these other factors explains
high electricity prices in California since May 2000. However, the authors
of the two market power studies believe, based on their results and on
results of other studies, that the case for the existence

2 In discussions with the California Independent System Operator, the body
that collects outage data, we were told that prior to the FERC study, outage
data had not been systematically reported by companies but that this
information was now being collected.

Page 9 GAO- 01- 857 FERC Study of Electricity Outages

of market power has been conclusively made and that this is enough to
warrant a policy response from FERC and the state of California.

FERC officials acknowledge that simply looking at outages and maintenance
records of generators is not sufficient to determine whether generating
companies are exercising market power. Accordingly, they told us that FERC
has recently implemented a more comprehensive plan for monitoring the
exercise of market power. Under this plan, FERC will continue to look at
outages and to determine if the number, type and duration of outages are
warranted. In addition, FERC will monitor generators? bids to try to detect
bidding behavior designed to exclude generating capacity from the market.
FERC officials also said they have notified electricity generators that
their ability to earn unregulated market prices for electricity will be in
jeopardy if they are found to be withholding power in order to drive up
prices. We did not evaluate FERC?s current plan for monitoring generators?
behavior.

We provided the Chairman of FERC with a draft of this report for review and
comment. We also discussed the findings in our report with authors of the
other two studies. Generally, FERC and the academic authors agreed with the
basic findings in the report. However, FERC took issue with our
characterization of its conclusion, saying that FERC had only concluded the
absence of evidence of withholding electric power, rather than the absence
of withholding to influence prices. In addition, FERC pointed out that it is
important to make a distinction between its study, which focused on
engineering reasons for outages, and the other two studies, which focused on
economic reasons for withholding electric power (see appendix II for a copy
of the FERC?s comments). In addition, two of the authors of the other
studies added several clarifying points that we have incorporated into the
report.

In responding to FERC?s first comment, we believe that our characterization
of their overall conclusion is correct. In the conclusion section of its
report, FERC made several statements. First of all, FERC stated that its
?staff did not discover any evidence suggesting that the audited companies
were scheduling maintenance or incurring outages in an effort to influence
prices.? On the contrary, FERC stated that ?it

appears that these companies accelerated maintenance and incurred additional
expense to accommodate the ISO?s [Independent System Operator] operating
needs.? FERC also pointed out the age and higherthan- normal usage of
generating units as mitigating factors in explaining outages. Finally, FERC
stated that its detailed site reviews are consistent Agency Comments

Page 10 GAO- 01- 857 FERC Study of Electricity Outages

with a finding that ?prices are driven by demand, not the companies?
maintenance practices.? On the basis of these statements, we believe the
report concludes that the companies they audited were not physically
withholding electricity in an effort to influence prices. From a practical
standpoint, a public statement, made shortly after the FERC?s outage report
was released indicates that others felt the FERC was reaching such
conclusions. For example, an article in the Los Angeles Times on February 3,
2001 quoted a spokesman for one of the generating companies as saying that
the FERC report affirms the company?s operating procedures in the face of
?incorrect and inflammatory allegations that we have somehow been
withholding power from our four plants in California.?

The distinction between physical and economic withholding was pointed out by
FERC in its second comment. We agree with FERC that the other two studies
were wider in scope than its review of generator outages. As we pointed out
in our report, a thorough and conclusive study of market power in California
would combine the market wide approach of the other two studies, with a
quantification of the extent to which outages or other supply disruptions
were caused by factors other than companies? attempts to drive up prices. We
have added clarifying language in the body of the report that makes the
distinction between the FERC report on physical outages and the other two,
which looked more broadly for evidence of market power.

FERC?s report comes on the heels of some of the most dramatic electricity
price increases in history. These price increases caused consumers, other
market participants, and members of Congress to question whether
electricity- generating companies have been charging unfair prices and
making very large profits at their expense. In short, the public and others
were looking for clear answers as to whether sellers of electricity in
California were withholding power in an effort to raise prices. In this
environment, FERC?s report-? focusing on whether unplanned maintenance or
outages occurred to raise prices?- was important. In addition, as the
federal government?s market monitoring entity, FERC?s views, opinions, and
orders clearly send important signals to the marketplace, including the
investment community, and influence public confidence. We believe that, as
the federal government?s marketmonitoring entity, FERC has an important
responsibility to fully investigate potential market power and clearly
report its results. In light of changes in the electricity industry as it
undergoes restructuring, and the changing role of FERC in overseeing this
industry, we recognize that

Page 11 GAO- 01- 857 FERC Study of Electricity Outages

FERC?s monitoring role is evolving and that its outage report was simply one
part of its ongoing effort.

To develop an understanding of the issues surrounding market power in the
electricity industry, we interviewed numerous economists from Stanford
University, the University of California, Berkeley, and the University of
California, Irvine, and reviewed written studies of market power and related
issues. We also interviewed officials from state and federal energy
agencies, including the California Public Utilities Commission, the
California Independent System Operator, and FERC.

To compare the FERC outage study and the other two studies on market power,
we reviewed the three studies, evaluating the methodologies used and the
results. After our initial review, we discussed our findings with FERC
officials and authors of the other studies. We also reviewed related studies
of market power.

To determine whether FERC?s methodology was thorough enough to support its
conclusion that generating capacity has not been withheld without legitimate
reason, we evaluated their methodology and results. We also discussed our
findings with state and federal energy officials and an economist at the
University of California, at Irvine who was familiar with all three studies.

We performed our work from May through June 2001 in accordance with
generally accepted government auditing standards.

Unless you publicly announce its contents earlier, we plan no further
distribution of the report until 14 days after the date of the letter. At
that time, we will send copies of this report to FERC and the authors of the
two studies. We will also provide copies to others on request. Scope and

Methodology

Page 12 GAO- 01- 857 FERC Study of Electricity Outages

If you or your staff have any questions about this report, please call me on
(202) 512- 3841 or Dan Haas on (202) 512- 9828. Other key contributors to
this report were Jon Ludwigson and Frank Rusco.

Jim Wells Director, Natural Resources and Environment

Appendix I: Study Titles and Author Information

Page 13 GAO- 01- 857 FERC Study of Electricity Outages

?Report on Plant Outages in the State of California,? prepared by the Office
of the General Counsel, Market Oversight & Enforcement and the Office of
Markets, Tariffs and Rates, Division of Energy Markets, Federal Energy
Regulatory Commission, February 1, 2001.

?Diagnosing Market Power in California?s Restructured Wholesale Electricity
Market,? Severin Borenstein, James Bushnell, and Frank Wolak, August 2000
[unpublished]. Severin Borenstein is a professor of business economics in
the Haas School of Business, University of California, and Director of the
University of California Energy Institute. James Bushnell is a lecturer in
the Haas School of Business, University of California, and a Research
Associate at the University of California Energy Institute. Frank Wolak is a
professor of economics at Stanford University and chairman of the Market
Surveillance Committee of the California Independent System Operator.

?A Quantitative Analysis of Pricing Behavior in California?s Wholesale
Electricity Market During Summer 2000,? Paul Joskow and Edward Kahn, January
2001 [unpublished]. Paul Joskow is the Elizabeth and James Killian Professor
of Economics and Management at the Massachusetts Institute of Technology
(MIT) and Director of the MIT Center for Energy and Environmental Policy
Research. Edward Kahn is a principal at Analysis Group/ Economics, a private
consulting firm. Appendix I: Study Titles and Author

Information

Appendix II: Comments From the Federal Energy Regulatory Commission

Page 14 GAO- 01- 857 FERC Study of Electricity Outages

Appendix II: Comments From the Federal Energy Regulatory Commission

Appendix II: Comments From the Federal Energy Regulatory Commission

Page 15 GAO- 01- 857 FERC Study of Electricity Outages (360063)

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 1- 800- 424- 5454 (automated answering system) Ordering Information

To Report Fraud, Waste, and Abuse in Federal Programs
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