The comments were filed by:
- AARP
- American Forest & Paper Association
- American Municipal Power, Inc.
- American Public Power Association
- Blue Ridge Power Agency
- Citizen Power
- Citizens Utility Board
- Coalition of Midwest Transmission Customers
- Connecticut Office of Consumer Counsel
- Delaware Municipal Electric Corporation, Inc.
- Electricity Consumers Resource Council
- Illinois Attorney General
- Industrial Energy Consumers of America
- Kennebunk Light & Power
- Maryland Office of People's Counsel
- Modesto Irrigation District
- Municipal Electric Utilities Association of New York
- National Consumer Law Center
- NEPOOL Industrial Customer Coalition
- New England Public Power Association
- New York Association of Public Power
- Office of the People’s Counsel for the District of Columbia
- Ohio Partners for Affordable Energy
- Pennsylvania Office of Consumer Advocate
- PJM Industrial Coalition
- Public Citizen
- Public Power Association of New Jersey
- Public Utility Law Project of New York, Inc.
- Virginia Citizens Consumer Council
The comments call for an examination of all components of power generator costs and revenues to ascertain whether FERC's market-based rate system is really achieving results for consumers superior to those under traditional regulation, where rates are based on reviewed prudent costs and an allowance for a reasonable return to investors.
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