A blurring of the state-federal jurisdictional lines between local distribution facilities and transmission facilities, between distribution utility services and bulk transmission services, and between retail rate matters and wholesale rate matters, is creating uncertainty among utilities, regulators, and legislators. Welton's Non-Transmission Alternatives is helpful in illuminating many of these developing issues. Even if FERC does not adopt all of its recommendations, the Article points to areas where FERC could helpfully clarify a number of these issues.
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