The main thesis of PWP-041 is that Transmission Congestion Contracts (TCCs) that are compensated ex-post based on nodal prices resulting from optimal dispatch by an ISO will be preempted by the strategic bidding of the generators. Thus, even when generation is competitive, rational expectations of congestion will enable generators to raise their bids above marginal costs and capture the congestion rents leaving the TCCs uncompensated. These conclusion is based on a Cournot model of competition across congested transmission links where an ISO dispatches generators optimally based on bid prices. First, Oren considers the case of one demand bus characterized by an elastic demand curve separated by a congested transmission link from a supply bus with many identical generators. Unlike the standard Cournot oligopoly result where prices converge to marginal cost as the number of suppliers increase, here the equilibrium prices converge to the demand price corresponding to the congested supply quantity. Thus, the generators capture all the congestion rent and the TCC for the link remains uncompensated. In a second example with two supply nodes of different marginal costs the equilibrium price at all nodes converges to the higher of the marginal cost so that the generators at the cheaper node captures all the congestion rent. The price distortion in the three node Cournot equilibrium results in a deadweight loss. Oren concludes that efficient dispatch requires active trading of Transmission Capacity Reservations. Supplanting such trading with passive TCCs that are compensated ex-post by the ISO based on the energy market outcome creates undesirable market power for the generators.