This is a brief response to Professor Stefan W. Krieger's lengthy review of the genesis and development of public utility regulation in the United States, in which he perceives that the settling of utility rate cases is a growing practice. Professor Krieger draws the conclusion that unanimous settlements are necessary to protect certain consumer groups. In this response, we suggest that Professor Krieger has misinterpreted regulatory history and reached a conclusion that is neither necessary nor conducive to reasonable regulation.

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