Comment of the Staff

Before the FEDERAL ENERGY REGULATORY COMMISSIONSan Diego Gas & Electric Company ))Complainant, )v. )) Docket Nos. EL00-95-000 et al.Sellers of Energy and Ancillary Services ) Into Markets Operated by the California ) Independent System Operator and the ) California Power Exchange ))Respondents. )Comment of the Staff of the Bureau of Economics and of Policy Planning1 of the Federal Trade CommissionNovember 22, 2000* This comment represents the views of the staff of the Bureau of Economics and of PolicyPlanning of the Federal Trade Commission. They are not necessarily the views of the FederalTrade Commission or any individual Commissioner.Before the FEDERAL ENERGY REGULATORY COMMISSIONSan Diego Gas & Electric Company ))Complainant, )v. )) Docket Nos. EL00-95-000 et al.Sellers of Energy and Ancillary Services ) Into Markets Operated by the California ) Independent System Operator and the ) California Power Exchange ))Respondents. )Comment of the Staff of theBureau of Economics and of Policy Planning1 of the Federal Trade CommissionI. INTRODUCTION AND SUMMARYThe staff of the Bureau of Economics and of Policy Planning of the Federal TradeCommission (FTC) submits this comment to the Federal Energy Regulatory Commission (FERC)on its Order Proposing Remedies for California Wholesale Electric Markets (Proposed Order) inthe above-captioned proceeding. The Proposed Order is intended to remedy deficiencies inmarket rules and institutions ...