The Companies responding to this General Investigation proceeding have provided a lot of excuses to the Commission as to why so many customers received multiple consecutive poorly estimated bills that led to dramatically high “true up” bills.
Originally, the Companies tried to convince the Commission and the public the problems
were mainly caused by the timing and size of the Derecho and Super Storm Sandy.
When the problems continued, the Companies started providing further excuses, but did
not take responsibility for their role in creating many of the problems themselves and compounded the problem further by making unreasonable demands for payments from the impacted customers. In Staffs opinion, they still have not taken that responsibility.
The Derecho and Super Storm Sandy undeniably played a significant role in the problems underlying this case. However, all along the way, the Companies made poor decision after poor decision with little to no thought as to how it might impact their customers.
These poor decisions lead to multiple and continued violations of their tariffs. Staff takes
these violations very seriously and believes it is time the Companies own up to their mistakes and provide the Commission with concrete evidence these types of problems
will not reoccur. Further, the Companies should be required to either correct the ongoing problems with their estimation routine or switch from bi-monthly to monthly meter reading.

Hurricane Sandy struck the service territories with large amounts of heavy, salt-laden, snow that tore down trees and power lines...

It is easy, and some may say unfair, to play Monday morning quarterback with the decisions of the Companies. Staff does not believe it is unfair to do so in this circumstance. A poor decision here or there is just that, a decision that did not work out.
What we have here is something completely different, poor decision on top of poor
decision on top of devastating storms on top of more poor decisions with no management
thought of potential impacts to customers. This is a pattern of behavior. It appears FirstEnergy had a plan for integration and was determined to follow through with that
plan no matter the result. Little consideration was given to the customers, “merger
synergy savings” had to be captured. Indeed the Companies suspected as early as
September of 2012 there may be problems, but did nothing to attempt to resolve them
until April 2013. At that point, the problems had become so widespread the Companies
had no choice but to try and address them. However, shockingly, the Companies
continue to act as though they were simply a victim of circumstance. Generally, Staff believes the Commission should send a strong message to the Companies that this type of behavior will not be tolerated, that the Commission believes the Companies did indeed violate their tariff in multiple ways and that continued violations will be looked upon
very unfavorably.

Bad historical usage data begets bad data and, thus, CAD believes the only way to correct the problem caused by the Companies’ failure to conduct bi-monthly reads of residential meters is to obtain one year’s worth of reliable data from actual monthly meter reads. It is the goal of the CAD that this matter be resolved in the best possible manner for customers of MP and PE, who have undeniably suffered - and, in some instances, continue to suffer - the ill effects of the Companies’ meter reading and billing practices.

Throughout the course of this proceeding, the Companies have attempted to place the
majority of the blame for their billing and meter reading problems on the Derecho that occurred in June 2012 and Superstorm Sandy, which occurred in October 2012. However, while the storms may have exacerbated the Companies’ existing problem, it is inaccurate to contend that the storms caused the billing problems so many customers have faced. In actuality, the evidence shows that the merger of Allegheny Power into FirstEnergy in 2011 and subsequent transition issues in the wake of the merger, including understaffing, transitioning from the Allegheny billing system to the FirstEnergy billing system, and the questionable timing of the meter route “renumbering” project, created this problem.

And then, when you look at the other capital that we're spending, it's block and tackle spending that typically is recovered from a regulated standpoint.

Residential sales, shown in the upper left quadrant, were up 0.9% for the quarter, which brings the annual sales flat to 2012. We continue to see modest customer growth in our Western service areas, while our East customer accounts were essentially flat. Average usage per customer has been impacted by home energy efficiency programs. For these reasons, we are expecting normalized residential sales to be down nearly 1% in 2014.

Michael J. Lapides - Goldman Sachs Group Inc., Research Division
Yes, 2 questions unrelated. First, on the transmission side. We've seen in the MISO and in New England dockets where interveners are seeking lower transmission base ROEs. If same things happens in some of -- whether it's the Southwest Power Pool, whether it's in PJM, how -- what do you think that tipping point is where we change or, I don't know, you're incentive or your desire to be a sizable investor in transmission in the U.S.?

Nicholas K. Akins - Chairman, Chief Executive Officer, President, Member of Executive Committee and Member of Policy Committee
I think, as long as transmission is, at a premium or equal to the state rates, we're in good shape. And I think, clearly, there is an incentive being placed on building transmission. We're happy with that. And if -- really, once again, the FERC needs to send some messages here that from a policy perspective that we want to continue building transmission in this country. And as long as that premium is at or above the state rates, then we're in good shape.

Brian X. Tierney - Chief Financial Officer and Executive Vice President
FERC was clearly, Michael, looking to attract a capital into this space. And what they've done with their ROEs has done exactly what FERC wanted to happen. So as long as they, as Nick was saying, as long as they continue to send a signal that they want increased investment in this area, we'll respond to that signal.

Nicholas K. Akins - Chairman, Chief Executive Officer, President, Member of Executive Committee and Member of Policy Committee
Okay, I think it's good -- I think, it continues to be part and parcel to the overall grid expansion that's going on in the resilience of the grid. And there's going to continue to be spin regardless. The question is, do you really want to satisfy that precursor of transmission being build out to respond to the generation retirements and so forth to optimize the grid so that you can do that as a prerequisite and then focus on the rest of the underlying system. That's what key. I think you got to get through this transitional process we're at in this industry. So transmission needs to be incentivized in that regard because that will provide the greatest benefit in terms of resiliency of the grid, but also in terms of the optimization of the resources that are attached to the grid.

The expected growth in electricity demand has not materialised. There is now a wide and growing margin of generation capacity over demand. A new gas-fired plant was commissioned last year and another one is due to come on stream towards the end of 2014. The construction of new wind-farms continues apace. While some of the older stations are coming to the end of their useful lives, none are on their last legs. If Ireland was left to its own devices, there would be no urgency about adding more generation capacity for many years to come.

*snip*

Plans by Eirgrid to upgrade the high voltage transmission network, and in particular to build three major lines in the southeast, the west and a new North-South line, reflect both the ongoing need to renew and strengthen the network but also the perceived requirement to accommodate additional wind-power units. If the Government's wind targets are excessively ambitious, some of the grid projects might not be needed. There is also a push from wind-energy companies, including State companies, to build more capacity designed for exporting power to the UK. If these plans go ahead, there would be yet more high voltage lines, on top of Eirgrid's proposals, from the midlands to the east coast, as well as further undersea interconnection to Britain.

Energy infrastructure is both expensive and controversial. *snip* Plans for new transmission lines, extra wind-farms and onshore gas exploration are meeting widespread resistance around the country and promise to dominate the local and European Parliament elections in May.

If energy infrastructure projects make economic sense, the political system must arbitrate the health, safety and environmental concerns that will inevitably, and quite properly, be raised. It is sometimes tempting to regard the objectors as locally oriented nimbies seeking to blackmail politicians who are pursuing necessary national priorities. Indeed this is hinted at in the government line on pylons and wind-farms, which takes it as read that the various projects are necessary to meet the requirements of development. But if the economic justification for the projects is flimsy, the balance of the argument is altered. In Ireland it has not been demonstrated that the continuing push for ever-greater reliance on intermittent wind-generated electricity makes economic sense, nor is it clear that wind is the least-cost path to reducing greenhouse gas emissions.

The people of West Virginia had made clear demands: put land and people first.  The companies did neither, but continued on their profit-driven rampage destroying huge swaths of the West Virginia mountains – one of the world’s most beautiful landscapes – with mountaintop removal for cheaper access to coal, exposing residents to toxic air pollution in order to provide the rest of the nation with cheap energy.  The decisions made in the early 1970s are what got us here today, with hundreds of thousands of people spending days unsure when they would be able to drink their water again, with many remaining unsure as pipe flushing and other cleanup procedures have been ineffective.

The state's electricity consumption exceeds its net generation, and currently more than one-third of power consumed in Maryland comes from the PJM grid.

In the meantime, we will continue to welcome your advice, based on your very long  experience on how to convince the American
public of the need and opportunity to  transform dirty energy systems to ones that  are cleaner and more efficient.

Communications. To achieve results, we must move the national narrative around clean energy and climate. Stories that show the economic benefits of a clean energy economy and positive, science-based discussions about clean energy, climate, and health are keys to progress. Fresh Energy has expanded our commitment to become a clean energy communications leader, as producers of the regional online news site Midwest  Energy News and in debate-changing strategic communications efforts.

Wind power is a major ingredient in the transition to a clean energy economy. But to make it work, we need transmission lines that
bring electricity from windy areas to urban centers. If we do it right, wind blowing on the Great Plains will keep the lights on in
Minneapolis, Chicago, and Detroit, creating new jobs, protecting our air and water, and reducing reliance on dirty coal power.  The Midwest’s transmission grid is managed by the Midcontinent Independent System Operator (MISO), one of the largest transmission organizations in the world. Fresh Energy has been working with MISO and a network of partners to plan for 17 new multi-value transmission lines in the region, ensuring they are financed fairly and designed in a way that maximizes clean energy use and saves  customers money. A strong, regional transmission backbone reduces dependence on coal plants. Determining how transmission lines are sited and routed—and how  landowners are compensated—is a crucial step. With our technical knowledge and commitment to community livability, Fresh Energy is playing a key role in this process. As Fresh Energy and its partners continue the push for more clean energy in Minnesota and the upper Midwest,
we’re setting the stage for the next set of transmission lines that will make or break our ability to fully harness the potential of the wind.