Grain Belt Express opponent Amy Harvey lives in the tiny town of Polo, Missouri.  I'm sure it was mere coincidence that Grain Belt Express recently opened an "office" in Polo for the purposes of doing business with all the landowners who are beating a path to Grain Belt's door to sign over their property early and cheaply.

Amy is Polo's version of Bree Van De Kamp, so it was inevitable that she would take the initiative to be a good neighbor and welcome Grain Belt Express to Polo.

She baked them some delicious, organic BANANA muffins,

and she made them an artsy "Welcome!" card

and she paid a visit to GBE's "office."

Unfortunately, the only one home at Grain Belt Express was intern Cari, who was killing time waiting for some emails of support from local government officials to show up. 

Cari relished the delicious muffins and wanted to know what was in them.  Happiness, Cari, just pure happiness!

I can't wait to see what Amy cooks up next...

The WV PSC staff filed a memo in the FirstEnergy General Investigation of customer service, billing and meter reading practices case yesterday.

The staff agrees with recommendations of many of the consumers who came before the Commission last month.

The staff requests the Companies provide the number of consecutively estimated readings for residential and non-residential customers separately.

As pointed out repeatedly by Jefferson County consumer Kery Fries, the companies have been skewing these statistics by including monthly read commercial customers in the numbers, but excluding annual read residential customers. 

And speaking of those "annual read" customers, staff believes that FirstEnergy's policy of requiring meter readers to use their personal vehicles is causing too many customers to be designated as "annual read" customers.

In other words, if your non-union meter reader drives a lowrider hooptie you may be designated an "annual read" customer, whereas if your meter reader was driving a company-owned 4WD pick up designed for higher clearance and better traction, you might receive readings more often. 

The staff also takes exception to the company's refusal to provide data on the number of complaints it has received from customers.

Well, sweet!  If Potomac Edison has to count every call that resulted in an adjustment to the customer's bill, I'm probably good for 5 or 6 myself.  If done Potomac Edison's way, my "complaints" probably wouldn't register.  Remember, Potomac Edison doesn't have a "complaint department" according to one of the customers who spoke in Shepherdstown.

I'm not really on board with the staff's analysis and recommendation regarding customer-supplied meter readings, though.  Staff seems to be under the impression that multiple bills are generated when a customer calls in a meter reading after receiving an incorrectly estimated bill.  While the customer will receive a new bill (and is informed of that during the phone call), the multiple bills customers have been complaining about are randomly generated at company initiative.  When FirstEnergy makes an internal adjustment to a customer's account without the customer's knowledge, a bill is generated.  These bills are being mailed to the customer, instead of being culled from the outgoing bill stream.  In-house adjustments should appear as line items on a customer's regular monthly bill, not as separate "restatements" of previously billed amounts mailed to the customer.

Also, the staff doesn't seem to see the problem with customers continuing to do the meter reader's job and call in their readings.  With very few exceptions, customers don't want to read their own meters when they are paying the company to do so.  Some do simply because they cannot afford to pay an incorrect bill, but this shouldn't be a requirement.

Staff recommends that pre-billing customer reads be done within a window of time, instead of on a certain day, and that post-billing customer reads only be accepted for a difference greater than 10%.

Staff also agrees with us that FirstEnergy has not fixed the problems with its estimation routine, but fails to recommend any corrective action.

And?  Is there a page missing here?  Let's get this fixed, before the winter heating season really gets underway and the service shutoffs begin.  They're still happening.

In a not at all surprising move today, the Kansas Corporation Commission conditionally approved the 750-mile Grain Belt Express Transmission project.  The project, proposed to plow through and ruin 370 miles of prime farmland in the state, has been greased since becoming the pet of Kansas Governor Sam Brownback when first proposed.  Ol' Sam apparently believed all the pie-in-the-sky promises he was made by a couple of Texas speculators, who saw opportunity to profit off the backs of hard-working Kansans.  Sam and his KCC Commissioners are now trying to hide behind some plainly illogical and assuredly "cooked" job numbers as cover for their betrayal of the people of Kansas.

135 jobs to operate and maintain the 370-mile length of this line in Kansas?  Who are we kidding here?  This is a ridiculous claim!  Once built, the line will be operated by a handful of jobs at a control center outside Kansas, hundreds of miles away.  These operators are already controlling hundreds of transmission lines, addition of Grain Belt Express won't cause an appreciable increase in operations jobs.  Every 10 years or so, a tree company will be hired to clear the right-of-way to be in compliance with operation standards, maybe, if they can't get away with ignoring it any longer.  When the line fails or is taken down by a natural disaster, a handful of specialized workers will be imported to Kansas to make repairs as quickly as possible to get it back in service.  Where are the operation jobs, Sam?  Does Sam think that an "operator" will be standing by every 2.7 miles, manually squeezing electricity through this line?  Or maybe they'll just stand on the prairie, cheering the electricity along on its path to "states farther east?"  Ridiculous!  I guess Sam and the KCC have no common sense that would allow them to view the illogical nature of these unsubstantiated job claims.

And that's just the problem here, folks.  KCC's approval was based on the unsubstantiated claims of the applicant.  Unrealistic claims and biased "studies" are a part of every transmission line application.  The applicant attempts to show its project is needed and will provide some benefit.  However, in states with knowledgeable and professional regulators, the information provided with the application is subjected to some expert scrutiny to verify its truthfulness.  Professionally regulated states will hire their own subject matter experts to study the application and provide testimony.  In addition, in professionally regulated states, other parties to the case will hire their own experts to review the information and file testimony.  Only in this way are exaggerated and untruthful claims weeded out to allow the truth to emerge and be considered by the regulators making the decision.

But, the KCC relied completely on two members of its own staff to provide "expert" opinion on subjects ranging from health problems related to EMF exposure to the reasonableness of the route.  Both staff members are electrical engineers.  Their expertise is in electrical engineering, not health, routing, farming impacts, oil operations, jobs, PJM and MISO electricity markets, renewable portfolio standards of eastern states, or any of the other myriad topics upon which Tweedledum and Tweedledee provided "expert" verification of the applicant's claims.  In its Order approving the project, the KCC claims:

The KCC makes it sound like the opposing parties failed to do their part.  The truth of the matter is that the opposing parties were prohibited from entering any evidence or testimony into the record, and were also prohibited from cross-examining GBE's witnesses to test the veracity of the claims made.  This is how the KCC and GBE maintained complete control of an unverified, biased body of evidence upon which to base approval.  This was not due process, but a double time race to approval before the truth was exposed.

The KCC claims that it based its decision on the "necessity and reasonableness of the location of the proposed electric transmission line, taking into consideration the benefit to consumers in and outside Kansas as well as economic development benefits in Kansas."

Here's how KCC "considered" consumers inside and outside Kansas:

Ridiculous!  The data upon which the conclusions were based was wholly unverified, and the conclusions themselves were based on questionable assumptions.

The KCC even rolled over and failed to condition the permit in any effective way.  The staff had recommended that the permit be conditioned upon GBE obtaining approval to construct the project from the other three states in which it is sited.  GBE objected, claiming that "federal siting approvals" could be substituted for state permission.  The KCC rolled over and adopted this condition, clearing the way for GBE to thumb their noses at the other three states, instead of "considering consumers outside Kansas."  I don't know about you, but I'm certainly not looking for Kansas to protect my interests, no matter what state statutes they adopt.

The second recommended condition included a requirement that GBE remain a "merchant transmission project."  GBE objected, most likely because it is looking to submit its project for regional cost allocation (ratepayer funding) in PJM and/or MISO (neither of which include Kansas, which is located in SPP).  Once again, the KCC rolled over and worded the condition to simply prohibit recovery of project costs from Kansas ratepayers.

Approval of Grain Belt Express in Kansas is a travesty of justice.  The KCC will now become the laughing stock of other state regulators.  But the battle now shifts to other states with strong regulators, like Illinois and Missouri, who perform their jobs with a little more professionalism, and perhaps to a fateful battle at the Department of Energy, Congress and federal court over federal eminent domain taking of private property in order to facilitate the profits of a private entity.  We're only just getting started...

This has been a long time in coming, but FirstEnergy was ordered on Friday to "submit a detailed plan for implementing audit staff’s recommendations and correcting journal entries reflecting an approximate $1.2 million refund to affected customers from its transmission-only subsidiaries with formula rate recovery mechanisms, including Trans-Allegheny Interstate Line Company, Potomac-Appalachian Transmission Highline, LLC, and American Transmission System, Incorporated."

The first time this problem reared its ugly head was during the July 2011 PATH Open Meeting to review its 2010 actual transmission revenue requirement.  At this phone "meeting" I notified PATH that I had found expenses of the Allegheny Energy/FirstEnergy merger in its PATH rates.

In September, FirstEnergy subsidiaries PATH and TrAILCo made entries to their quarterly FERC financial filings to effect a credit for amounts wrongly charged to ratepayers in violation of the company's "hold harmless" guarantee to the Commission that it would not charge merger expenses to ratepayers except under certain circumstances.  Over a million dollars was credited, but because PATH and TrAILCo made the correction in the normal course of business, it did not credit ratepayers for interest on the amounts wrongly recovered.

Throughout the fall of 2011, PATH counsel continued to argue with me in discovery about recovery of merger expenses, refusing to own up to the fact that other merger expenses had been recovered.  In October, PATH filed a motion to dismiss the first formal challenge, claiming that the involvement of Ali Haverty and myself in its annual update review was costly to ratepayers.  In response, I pointed FERC to the more than $1M savings ratepayers had realized due to my identification of merger costs wrongly included in PATH's revenue requirement that were subsequently reclassed on the company's Form No. 1 filings.

Shortly thereafter, FERC notified FirstEnergy that it was commencing an audit to determine if the company had complied with the Commission's order in the merger case. 

In December, TrAILCo filed a revision to its revenue requirements to correct merger costs "inadvertently" recovered.  It claimed this error had been noticed during an "internal staff review."  Right....

If you take time to read FERC's FirstEnergy merger order, you will see that parties to that case had argued that adequate safeguards did not exist at FERC to prevent FirstEnergy from ignoring the hold harmless stipulation and recovering merger costs.  FERC poo-poo'd this idea, insisting that their processes would be adequate to catch any wrongful recovery.

And then FirstEnergy went ahead and recovered the merger costs anyhow!  Did FERC's processes identify this wrongful recovery?  No, I did.  How embarrassing!

FirstEnergy made a whole bunch of promises it never intended to keep in order to get its merger with Allegheny Energy approved.  In addition to wrongly recovering merger costs in FERC jurisdictional rates, the company has saddled its West Virginia ratepayers with "acquisition adjustment" premiums flowing from its merger, as well as causing hardship to a whole bunch of distribution customers by cutting its meter reading services that resulted in huge erroneous bills and service shut offs.

FirstEnergy's past bad deeds seem to be catching up with them lately, and the group of people and entities enjoying the show keeps growing.

Counsel for the West Virginia Citizen Action Group filed an appeal of the West Virginia Public Service Commission's approval of a settlement in the Harrison case this morning.

The filing asks that the West Virginia Supreme Court  grant its Petition for Suspension of the October 7, 2013 Plurality and enter an order vacating the Commission’s decision in its entirety.

It's just too bad the pendulous nature of it prevented it from being filed yesterday morning, before FirstEnergy's timely earnings call, but I'm sure the financial analysts will have plenty of time to give it a look before the EEI conference next week.  Nobody's going to care much about Tony's transmission spend after all.

You can download a copy of the filing here.

The good folks of Illinois put one of our successful PATH opposition tactics to work against Clean Line Energy Partners in their state.  Landowners in the path of the Rock Island Clean Line (RICL) project have sent written notice to the company that they do not wish to be contacted by land agents or other company representatives unless and until the company is issued a CPCN by the Illinois Commerce Commission.

The Illinoisans made one small modification though, they did not limit contact by U.S. Mail.  After all, power company propaganda makes a great, free lining for the chicken house or pig pen.

And, because it is the only avenue left to the company after failed appearances at recent public comment hearings, they have been sending mail to affected landowners.  One recent, pointless letter from Clean Line's Hans Detweiler

served as cover for a company FAQ.  The FAQ attempted to respond to recent information about the project posted on the BlockRICL website and Facebook page, but I think a lot of RICL's information is misleading or just plain wrong.  Here's where I think RICL got it wrong:

Rock Island Clean Line Frequently Asked Questions

Q: What is the Rock Island  Clean Line?

A: The Rock Island Clean Line will be part of the nation's critical infrastructure that will help power our homes, communities, and the clean energy economy. The project will consist of an approximately 500-mile, overhead, direct current (DC) transmission line. The line will be capable of transmitting up to 3,500 megawatts of new renewable  energy from northwest Iowa and the surrounding region  to communities in Illinois  and in states farther east. The project will deliver enough clean, renewable energy to meet the needs of over  1.4 million American  homes.

The Rock Island Clean Line is not part of any national infrastructure plan and need for it is not critical.  RICL is intended to transport electricity generated in western Iowa to eastern Illinois, where it will be connected with the PJM Interconnection system to be sold to consumers in east coast states.  RICL will not power homes in the communities being asked to sacrifice to host the transmission line.  The economic benefits of RICL will flow into the pockets of Texas-based Clean Line Energy Partners, LLC, not into the pockets of the landowners hosting the project.

Although the line will be capable of transmitting up to 3,500 megawatts of energy, it only has firm transmission injection rights to deliver 700 MW of energy into PJM.  RICL may never deliver its claimed capacity upon which it calculated supposed “benefits” of the project. (Rebuttal Testimony of Steven Naumann, ComEd, ICC Docket No. 12-0560).

RICL makes much of the claim that its project will deliver renewable electricity to “states farther east,” however RICL has no customers, and has not produced any commitments or desire for its product from “states farther east.”  In fact, eleven east coast governors have written to congress, ten of them twice, stating that importing renewables from other states via long distance transmission lines would hamper renewable energy and economic development in their own states.  The “states farther east” do not want or need what RICL is selling.

Q:What will the project cost be  and  how will the Rock Island  Clean Line  be funded?

A: The Rock Island Clean Line is estimated to cost approximately $2 billion. Clean Line Energy intends to fund the development costs of the project and will sell transmission capacity to renewable energy generators  or to the buyers of the clean energy being delivered on the line.  Clean Line is not seeking any federal or state funding.

RICL has also shown its intention to ask for regional cost allocation for its transmission project.  RICL has proposed in filings with PJM and FERC that its project could be considered a reliability or market efficiency project under PJM’s planning process and that the company may bid the project in future transmission opportunity windows.  If RICL is successful in having all or part of its project regionally allocated, all PJM ratepayers could be ordered to fund the project, including those in Illinois.  If ordered to be built for reliability or economic reasons by PJM, RICL would be eligible to apply for federal transmission incentives, including return on equity adders and guaranteed recovery in the event of project abandonment.  The financing and cost of RICL is not certain.

Q:Will  Illinois ratepayers have to pay for the transmission line?  Will rates go up because of the Rock Island Clean Line?

A: No. There is currently no method for Rock Island Clean Line to charge Illinois ratepayers for the cost to build  the Rock Island Clean Line. If any such way were to be developed in the future, Rock Island Clean Line has agreed to re-apply  to the Illinois Commerce Commission (ICC) for  permission in a new proceeding to do so.

If RICL were to “develop” a way to charge Illinois ratepayers for its project in the future, that way would be through regional cost allocation via the PJM tariff.  The Illinois Commerce Commission has no authority to deny PJM’s assignment of cost responsibility for a project, and therefore its “permission” is not necessary.

There are three potential sources of money to fund transmission lines: government money, ratepayer money  ("cost allocation"), or private money  (merchant projects).  The Rock Island Clean Line is not using government, or taxpayer, funds.  There are no government subsidies available for transmission lines. The Rock Island Clean Line is not using ratepayer money.  There is no mechanism to allocate the costs for a project like Rock Island to ratepayers. Rock Island is utilizing a merchant model (private money) whereby only those wind energy developers or utilities that use the line will pay for it.

For now.

The Rock Island Clean Line will decrease wholesale electricity prices for Illinois consumers. In fact, the project will reduce wholesale electricity prices in Illinois by $320 million in its first year of operation, with additional savings in later years. Because electricity in Illinois is deregulated, per the law of supply and demand, Illinois residents and businesses can benefit from reduced electricity costs because the Rock Island Clean Line will significantly increase the amount of electricity supplied to Illinois.

RICL has failed to produce any reports or studies to back up its claim that it will reduce prices by $320 million.  Until RICL backs this up with figures, it’s pure fiction.  Any “savings” would be temporary as markets stabilize.  In addition, if RICL opens new supply lines for electricity into PJM, it could cause prices to rise over the long term as cheaper electricity flows to pricier PJM markets.

Q: Can I grow crops or build anything under the transmission line?

Transmission lines can prevent aerial spraying and irrigation, and construction can damage drainage tile and compact soil.  Transmission lines can also interfere with GPS equipment.  So, the answer is that you can try, but you probably won’t be very successful without extra cost and effort.

A: Clean Line will acquire easements, but the land will  still belong to the landowners and can be utilized for  activities  such as farming, grazing cattle, and other activities  that do not interfere with the operation of the line.  Farming of row crops can continue under the lines. There will be sufficient clearance under the transmission line to grow full-height crops, not including tree crops, and to operate standard farm equipment. Clean Line Energy must comply  with the  National  Electric Safety Code and  North American  Electric Reliability Corporation Standards to ensure the safe and reliable operation of the transmission line.

Landowners will still own the land, including the burden of paying property tax on the portion containing RICL’s transmission line.

Clean Line estimates that the right-of-way needed for the Rock Island Clean  Line to  meet operating standards will be between 145 to  200 feet  wide; however, the  line will directly impact  much less land than  that.   Property taken out of production by the transmission line foundations will typically comprise less than 1% of the easement property.

Written by Texas wind speculators, not farmers.  Read with skepticism.

Q: Will landowners be compensated if the transmission line is on their property?

A: Yes. Clean Line Energy is committed to compensating landowners fairly.  There are three primary components to landowner compensation: an easement payment, structure payments, and payments for damages. The total amount of compensation for landowners who  have structures on their  property will be more  than 100% of fair market value of the easement area.

The easement payment  is based on the  area  of the easement, calculated  in acres,  and the fair market value of the  land within the  easement. Fair market value is determined through  a market study of recent sales in the county.   Clean  Line will pay 90% of fair market  value of the  easement area.

How will “fair market value” be determined?  Most likely by an out-of-state appraiser who will never visit your property but will research land sales in your county and calculate an “average” of selected land sale prices to apply to your unique land.

Structure compensation is calculated based on the type of structure and the number of structures. The landowner may choose to receive either a one-time payment or a series of annual payments. Annual payments will be made as long as a structure is on the easement. The annual payments range from  $500 to $1,500 per structure or  the one-time payment ranges from  $6,000  to $18,000 per structure.  Depending on the land, and other engineering conditions, we expect 4-6 structures per mile.  Other payments may be made for damages in certain circumstances such as crop  damage, soil damage,  irrigation  or drainage  interference.

Who determines “damages” and their value to the landowner?  Do not sign any agreements with RICL without first consulting an attorney and tax advisor of your own choosing.  You do not have to accept what RICL is prepared to offer.  You may write your own compensation contract, or simply hold out and watch RICL’s offers rise the closer you get to an eminent domain condemnation proceeding.  Eminent domain is an expensive, time-consuming process RICL doesn’t want to engage in.  The landowner holds all the cards in negotiation!

Q:  How will Clean Line address impacts of construction to farmland?

A: Rock Island will work  to prevent and repair agricultural  impacts associated with the construction process.  Rock Island will work with  landowners to identify drainage  tile locations prior  to construction and minimize impacts  to such tile.  For damages  that  cannot be avoided,  Rock Island will decompact soil, repair  or  replace field tile, and take other steps as needed.  Rock Island will compensate landowners for  damages incurred as a result  of construction or  maintenance on their  property.  Rock Island has also committed to  pay for crop damages due to  construction and crop damages  that  may occur  due to maintenance associated with the  transmission line.

Rock Island Clean  Line has an Agricultural  Impact Mitigation Agreement with the  Illinois Department of Agriculture that  discusses  these  measures. This agreement details the extensive efforts  Clean  Line will make to  mitigate impacts  to agriculture.  The Agreement is incorporated as a part  of the easement  agreement Rock Island Clean  Line will  present to landowners.

Unless all these promises are put in writing within the four corners of your signed and recorded contract with RICL, they are nothing but empty promises.  In addition, which party will determine damages and define the effectiveness of repairs?  Don’t trust your land to empty promises by out-of-state limited liability corporations!

Q: Will Illinois benefit from construction jobs and tax revenues from the Rock Island Clean  Line?

A: Illinois will benefit from the  Rock Island Clean Line in several ways. The  line will be a $600 million investment in Illinois providing local jobs and tax revenues  and bringing  a new low-cost clean energy resource into  Illinois.

Rock Island is committed to using qualified  local and regional contractors whenever practical to construct and maintain the transmjssion line.   Examples of local jobs resulting from the construction of the line include  surveying, silt fence construction and pouring concrete. Rock Island has selected Kiewit Power to provide construction management services for  the project.  Kiewit cannot and will  not  perform the construction of the 500 mile line on its own.   Kiewit has substantial expertise with using local labor  and local services  to assist with the construction of major  infrastructure projects. Kiewit also has significant  experience working with landowners to minimize the impacts of construction to existing land use and to return land to pre-construction condition. Rock Island is dedicated to preserving the productivity of farmland. Kiewit's like-minded commitment to these goals is one of the reasons we've selected  them  for  this project.  Rock Island Clean Line has also committed to using multi-craft union  labor.

Ask if RICL or Kiewit have signed any legal contracts to use local/union labor.  We are not aware of any.  It would be prohibitively expensive for RICL or its contractor to have to negotiate with surveyors, concrete companies and silt fence installers in every town along its 500-mile length.  Expect that these services will be subcontracted to another entity that may or may not employ local labor for very short term projects.  RICL is committed to constructing its project as cheaply as possible, and that includes the price of labor.

While RICL may pay a minimal amount of property taxes on its infrastructure in your county, it will have a greater impact by devaluing properties to result in a lower assessed value that translates to a lower tax base to support the same level of county services.

Q: Will Rock Island use  eminent domain?

A: Rock Island intends  to reach fair and reasonable  voluntary agreements  to acquire easements from landowners, allowing plenty  of time  for  discussion.   Rock Island has not applied for  eminent domain  from the Illinois  Commerce Commission at this point and does not  intend to do so unless and until all reasonable, voluntary efforts at easement acquisition are exhausted.

RICL will not “apply for eminent domain” from the Illinois Commerce Commission.  The ICC is not a court that can condemn property and take it through eminent domain.  Only a court and jury of your peers in your own county can determine the amount of compensation you will receive in an eminent domain taking. 

RICL claiming it does not intend to “apply” for eminent domain unless you refuse its offers is not giving the landowner a choice of whether to sell, it is a threat to agree, or else.

Rock Island has applied for  a Certificate of Public Convenience and Necessity (CPCN) from the  Illinois Commerce Commission to operate as a public  utility in Illinois.  This is a requirement under  Illinois law in order to construct and operate a transmission line in the state of Illinois. It is also necessary to have a CPCN prior to seeking eminent domain; however, as stated above, Rock Island does not  intend  to apply for  eminent domain  unless and until all reasonable, voluntary efforts at easement acquisition are exhausted.

A grant of CPCN and public utility status from the ICC is the power to take your property “for public use” through the courts by use of eminent domain.  No further action before the ICC by RICL would be necessary.

Q. Will Rock Island take farm land out of  production?

A: Rock Island will acquire  easements, but  the land along the route will still belong  to the landowners and can be utilized for farming, hunting, and other activities that do not interfere with the reliable  operation of the line.  Less than  1% of the easement area that Rock Island Clean Line is seeking will be permanently taken out  of agricultural production, due to the footprint of the transmission structures.

If a landowner grants an easement for the project, RICL will control the landowner’s use of the entire easement in perpetuity.

We have carefully developed a compensation package that  includes an easement payment and structure payment which, when combined, will compensate landowners at or  beyond 100% of fair market value of the  land that comprises the  easement area.

Q: Will  the Rock  Island  Clean Line transport wind  energy? Or will other fossil fuels be transmitted over the line?

A: The Rock Island Clean  Line starts in an area  of northwestern Iowa that  has some of the best wind energy  resources in the country. Wind  energy  is the energy  resource that makes economic sense  to  be developed and shipped  over  the  Rock Island Clean  Line.  There are other areas  around  the  country that  are  better suited  for the development of fossil fuel power  plants - areas  that would  not  require the developer to  pay the additional  expense for  transmission that  Clean  Line will charge  wind companies that choose to ship power  over our  line.

RICL is no different than “mine mouth” fossil fuel generation plants that burn fuel where it’s harvested and ship electricity via high voltage transmission lines to point of use.  This same centralized generation and transmission method has been in use for more than 100 years.  However, technologically advanced, small-scale, point of use generation, such as roof-top solar, is now revolutionizing the way we produce and use electricity and is seen by the utility industry as a “threat” to their longevity.  Clean Line is a dinosaur that may never be used.

Legally, transmission companies are  not allowed  by the  Federal  Energy Regulatory Commission (FERC) to  prohibit  certain  types of energy,  but as a practical  matter, wind energy  is the resource that  would  be economically advantaged  by a project like this.  It would  not make sense  to  build a fossil fuel power  plant a long distance  from a where the power  is needed, when  a developer could choose to  produce the electricity much closer to the energy  demand.

Fossil fuel generators have been building generation plants near fuel sources and shipping the electricity produced long distances to points of use for 100 years.  Clean Line would be no different.  If there is a cheaper way to produce electricity to be shipped via Clean Line, that is the kind of electricity that will flow across the lines.  It also does not make sense to produce electricity from wind in Iowa and ship it to the east coast, when the east coast has a better wind resource in the Atlantic, located just 12 miles from load centers!

Q: Did east coast governors write Congress a letter opposing the Rock  Island Clean Line?

A: No. In 2009, ten  eastern governors did write  a letter to  leaders  in Congress regarding renewable energy  development. The governors speak  to their support for  renewable energy and to their  opposition to  subsidies  for  transmission lines for  remote renewable resources.

That’s right!  And RICL is one of those remote renewable resources that depend on transmission lines that the governors opposed in their 2010 letter!  The letter opposed “..subsidizing distant terrestrial wind resources which would stifle economic recovery and growth in the East…” and perfectly describes RICL!  But there were actually TWO letters, one in 2009 and one in 2010.

The  proposal  referenced in their  letter for such subsidies was not  passed into  law. The letter is in fact fully supportive of projects like the Rock Island Clean  Line, as the  Rock Island Clean  Line is not  receiving any federal  subsidies.

In fact, the letters opposed projects like RICL. 

2009 letter  Read it for yourself.

2010 letter  Read it for yourself.

The governors' letter was written and sent  prior  to the  start of development of the  Rock Island Clean Line and does not  mention  the  Rock Island Clean  Line.  In the letter, the governors "support the development of wind resources for  the  United States  wherever they exist" and highlight their  desire for a level  playing field for  renewable energy development. The  Rock Island Clean  Line is consistent with that  level playing field for  which the governors advocate in their  letter.

RICL has taken great liberty with the above quote from the 2009 letter.  In its entirety, here’s what the quote said, which is the exact opposite of the meaning ascribed to it by RICL:

“Current legislative proposals focused on transmission, in contrast, would designate national corridors for transmission of electricity from the Midwest to the East Coast, with the costs for that transmission allocated to all customers. While we support the development of wind resources for the United States wherever they exist, this ratepayer-funded revenue guarantee for land-based wind and other generation resources in the Great Plains would have significant, negative consequences for our region: it would hinder our efforts to meet regional renewable energy goals with regional resources and would establish financial conditions in our electricity markets that would impede development of the vast wind resources onshore and just off our shores for decades to come.”

The truth is that “states farther east” do not want or need RICL.  If RICL is permitted by the ICC and built in Illinois, the landowners and ratepayers of Illinois may be stuck with an expensive, unneeded dinosaur!  Say no to RICL and its dishonest portrayal of facts.

In the wake of the WV PSC public comment hearings on the general investigation of Potomac Edison/Mon Power billing, meter reading and customer service practices, the PSC ordered  "FirstEnergy to address the substance of the complaints voiced at the hearings."  The Commission gave FirstEnergy 15 days to accomplish this task after the hearing transcripts are filed.

Today, the last of the transcripts were filed.  So this means "the substance" of your comments will be addressed by November 20.

Well, good luck there, FE.  Not only is "the substance" a very non-descriptive term, but "address" is one of those weasely verbs that have multiple meanings.  And then, hey, let's take a look at those transcripts!  Some of it is completely unintelligible, or just plain wrong.  I hope FE took notes like I did...

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Ever made a pot of soup and added too much salt?  If you throw in a potato, that will absorb some of the salt, but then you've got too much potato.  So, you need to add more water.  But then it gets tasteless, so you add some more spices.  And then it gets too salty, so you add a potato... 

This is how FirstEnergy's West Virginia subsidiaries' usage estimation process has become FUBAR.  The only way to fix it now it to dump out that pot of soup and start fresh.

And the only way to start fresh is to read every customer's meter, every month, for at least 12 consecutive months and start with fresh data.

This fact was made perfectly clear to me during my personal "customer service" moment during the WV PSC public comment hearings in Shepherdstown last week.

After witnessing customer after customer being whisked off backstage "to be taken care of" by Potomac Edison personnel after they complained to the Commissioners about their service during the hearing, I started to wonder if the customers were being tied up, consumed by wolves, or simply given Potomac Edison beer cozies and pats on the head before being sent on their way.  Curiosity got the better of me when the murmur of an argument somewhere off to stage left escalated into shouting clearly heard throughout the auditorium, and resulted in several bored police officers running through the auditorium to break it up and make the customer move 25 feet away from the Potomac Edison employee he was harassing in the hallway.  I simply had to visit the lion's den for myself after the hearing ended!

So, I soon found myself in Potomac Edison's little backstage Happy Town, where Chrissy was eager to solve my problem.  She spent a while studying her computer before admitting that she really couldn't help me and went to fetch "analyst" Chris.  He spent a bunch of time staring at his computer too.  All this chin scratching to figure out why my usage was overestimated by 800 kwh on my last bill, and to assure me that upcoming planned estimates would not be based on "catch up" amounts from the prior year.  Chris finally concluded that Potomac Edison's estimation process was correct and wouldn't result in incorrectly estimated bills over the winter.  But he could not explain what had failed in my most recent bill that resulted in a rather severe over estimation.  If they couldn't figure out what went wrong last month, how could they know that it wouldn't reoccur?  The assurances I received were so useless, I started wishing for a Potomac Edison beer cozy to take home as a consolation prize, but it appeared to be locked away somewhere off site, along with Chris and Chrissy's senses of humor.

I did enjoy listening to the "private" conversation going on in the next cubicle where one happy customer referred to a customer service representative as "that brat."  Chrissy failed to be amused.  I got the idea that she thinks her fellow customer service representatives are never rude or unhelpful.  You just keep telling yourself that, Chrissy.  I wonder if there's a Rude Customer Service Representatives Anonymous chapter in Fairmont?

"Hi, my name is Brat and I'm rude."
"Hi, Brat!" 
"This week, I told a customer that we only had to read her meter once a year." 
"That's okay, Brat!" 
"And then I made her go out and read her own meter, although she told me she only had one leg and the porch was covered in ice." 
"One Day At A Time, Brat!" 
"But then I told her she had read the meter wrong and I was going to have to charge her a penalty for that."
"You can do better tomorrow, Brat!" 
"And then she asked to speak to my supervisor, so I made her wait while I answered the Giraffe Riddle on Facebook, and then I hung up on her." 
"Ohhh, Brat, we love you anyhow!"

The timer on my patience finally got close to zero, so I thanked my Happy Town guides for their time and got up to leave.  That was apparently the cue for Creepy Supervisor guy to get in my face and ask me if I had been helped.  Oh, c'mon, dude, you were standing right there listening to this whole sad spectacle and I'm sure you weren't doing that because you're hard of hearing! 

Silly, silly, silly!

So, here's what's wrong with FirstEnergy's estimation process -- it's broken and cannot be fixed!

When FirstEnergy stopped reading electric meters to save money in the fall of 2011, it created a string of inaccurate data.  In the fall of 2012, when this bad data started being used to calculate new estimates, the problem pancaked into some really crazy bills.  Then FirstEnergy thought they could devise some method to tweak their algorithm that would set things right.  Only that didn't work.  They tweaked some more.  And tweaked some more.  And tweaked some more.  What's left is something that is now a completely useless mess.  FirstEnergy needs to quit dumping time and money into future tweaks and begin rebuilding an accurate data base.  At their own expense, of course.

In looking over my notes and talking to reporters and customers in the wake of the Potomac Edison/Mon Power General Investigation public comment hearings in Shepherdstown and Fairmont last week, it's hard not to notice that certain similarities keep popping up in unrelated customer stories.

1.    FirstEnergy's customer service center is rude, misinformed and unhelpful.

Representatives have told customers it is only required to read meters once a year, twice a year, or other incorrect intervals.

"I waited on the phone an hour and a half, like my time doesn't mean anything."  -- Customer Sonny Spurgeon in Shepherdstown

"We've been treated like trash!" -- Customer Richard Hamstead in Shepherdstown

"The term "customer" implies we have made a choice to purchase electricity from Potomac Edison.  We are not customers, we are ratepayers." -- Customer Patience Wait in Shepherdstown

"It is clear that FirstEnergy’s allegiance is to the almighty dollar, not its West Virginia customers." -- Customer Keryn Newman in Shepherdstown

"The PSC said I should have been arrested for stealing electricity."  -- Customer Sonny Spurgeon in Shepherdstown

"Seniors have been asked to read their own meters in horrible weather."  -- Maryland Potomac Edison Customer Doug Kaplan

"This company is no longer our local electric company and needs better public relations and communication with the public."  -- Berkely Co. Commissioner Elaine Mauck in Shepherdstown

Customer Amanda Newcome is outraged by Potomac Edison's customer service reps. who don't care, act like she doesn't have an issue, and don't want to help her.

Customer Mike Nemec has spent 30 minutes on the phone just trying to call in a meter reading.

Customer Lucinda Harden:  Tried to call Potomac Edison but got put on hold so long she gave up.  She can’t hold the phone that long.  In August, she tried to speak to "the complaint dept." but was told they have no complaint dept.  Talked with someone named Camille, who sent her to supervisor Kim, who was a "nasty lady."  Was told, "we're playing catch up in June" and in July she must have used more electricity than what was needed because they estimated off the month before.  She was transferred to Wendy from floor support, who put her on a payment plan so she could pay the bill.  Wendy wanted her to go read the meter, and she did, even though she is disabled and it was difficult to do.  They want her to read the meter every month from now on.  They sent her a detailed account history from July 2012 – July 2013, which only had 3 actual readings.  She has never seen a meter reader since Potomac Edison took over.

2.      It's not about the storms!

It is about a 5-letter word, but that word is "greed," not "storm." -- Customer Kery Fries in Shepherdstown

Storms are foreseeable, Potomac Edison should be adequately staffed to plan for them.

"It must be new if meter readers go out for downed wires.  I'm a volunteer fireman and I never saw a meter reader come for downed wires." -- Customer Kevin Borher in Shepherdstown

3.    FirstEnergy is not adequately staffed to provide customer service. 

"Most offensive is the suggestion from FE that customers should call in their meters.  It’s not the ratepayers job – it is built into the rates and billing that they will do their job.  I wonder whether there has been a business decision to keep meter readers at a low level and shift burden to ratepayers to save money.  In the grocery store we have a choice of full-serve or self-serve checkout.  Here we don’t have the choice.  Has there been an effort to change billing to save money for the company?" -- Delegate Stephen Skinner in Shepherdstown

Meter reading staff in Jefferson County cut to 5 after merger.

Todd Meyers says it takes 3 weeks to train a meter reader.  If meter readers are being used to restore power, what job are they doing? 

Potomac Edison has been hiring temporary meter readers.  Once the investigation goes away, will the temporary meter readers be let go?

Gene Hutzler has made numerous requests for the company to trim vegetation interfering with lines, but nothing has been done.

"FirstEnergy is a union-buster." -- Customer Danny Lutz in Shepherdstown

"It's not our job to read meters, it is our job to pay the bill!" -- Customer Meredith Wait in Shepherdstown

4.    FirstEnergy's customer usage data is hopelessly skewed due to numerous estimates and attempts to tweak the estimation routine that have caused even more inaccurate data.

"I have a bill with 5 consecutive estimates since April." -- Customer George Rutherford in Shepherdstown

"I'm getting two bills every month.  Something is wrong here." -- Customer Janet Jeffries in Shepherdstown

"8 out of 13 bills have been estimated – April, May, June were estimates.  February said no usage at all.  What does this do to future estimated readings when there is so many estimates?" -- Customer Sharon Wilson in Shepherdstown

5.    FirstEnergy's merger has hurt customers.

" A mistake on FirstEnergy’s part should not become an 'emergency' on our part. There’s no reason customers should be asked to put up with this kind of incompetence, especially when the company continually ties its excuses to merger activity. All of this has come at a great cost to customers.  Now it’s time for FirstEnergy to shoulder some of the financial burden it has created."  -- Customer Keryn Newman in Shepherdstown

"How can we set budgets for small businesses with these inconsistent bills?  This is hurting businesses." -- Customer Meredith Wait in Shepherdstown

"This is not a game, not a numbers problem, it’s a human problem.  People are suffering – you all go home to a warm house and a meal.  Think hard about it.  I'm tired of corporate crap – you need to care about people." -- Customer Laurie Scott in Shepherdstown

Walter & Gerri Seager of Damascus, Maryland, on their second home in Harmon, WV:  They have paid an electric bill every month for the past 14 months, most of which were estimated, and then about a month ago got a bill for more than $5,300.  They brought in 3 master electricians to make sure nothing is wrong in their house, and nothing is wrong.  The bill still averages more than $500/month for a home that is only used several days a month by 2 people and has non-electric heat and hot water.  Something is wrong at the electric company, not at the Seager's end.
 
There were numerous suggestions for the PSC:

1.    At company expense, read meters monthly for at least one year to gather accurate data for future estimates.  -- Customers Fries, Hamstead, Wait, Newman, Hutzler, Kaplan, Mauck, Rutherford, Skinner, Wilson, Nemec, and others.

2.    Privatize meter reading services so that failure to perform service does not produce financial benefit for FirstEnergy.  -- Customer Kery Fries in Shepherdstown

3.    $5.00 customer charge should be explained on every bill, and any amounts not used to read meters as required should be refunded to customers.

4.    PSC and Consumer Advocate must zealously guard against abuse by monopolies in West Virginia's regulated environment.

"There is no excuse for this kind of abuse of captive customers in a regulated environment." -- Customer Keryn Newman in Shepherdstown

5.    Require FirstEnergy to take actual readings for new customers for one year.  They should not be allowed to estimated based on prior customer usage.

6.    FirstEnergy should provide rebates to customers who read their own meters or go "paperless."  These customer actions currently save the company money, not the customers.

7.    Why don't we have smart meters?

"Why is it we still have horse & buggy meters?  Why not digital meters?  Why not smart meters?" -- Customer Duane Thompson in Shepherdstown

8.    Anyone calling Potomac Edison should receive a follow-up letter with a postage-paid return post card addressed to the PSC for rating the service received.

9.    The PSC should hold general public hearings in 4 different quadrants of the state yearly to hear from the public and improve communication and service.


At the hearing, the PSC shooed the customers with the most shocking stories to FirstEnergy's "customer service" area backstage.  I've been asked by a reporter if that was effective -- aside from the one gentleman who could be heard yelling from that area after he disappeared and was told by the police to stop harassing Potomac Edison personnel, and my own personal experience, I don't know.  If you visited the "customer service" reps. and have a story to tell, let me know.

Potomac Edison also had a story to tell the PSC, complete with Power Point presentation.

Ken Strah, the estimating guy, said they have adjusted their estimation algorithm to not perpetuate last year’s bad estimates, and implemented enhancements to the estimation process to better predict usage of estimated bills (but customer testimony proved that’s not working, as incorrect estimates continue).

Jim Painter, the meter reading guy, said the company will “focus on minimizing estimates” but snow will prevent them from reading meters (more excuses, YAY!)  They are still looking at their estimation routine with EPRI and should be done in December. 

Meanwhile, the company continues public outreach – "Call us!"  You need to call them to continue THEIR public outreach?  FirstEnergy advised everyone to get on their Average Payment Plan to smooth out the company’s estimation errors.

WV Operations Director Holly Kauffman says the company has shown “continuous improvement.”  She never said the word "merger" once, although that seems to be the source of all these problems.  Holly says she is committed to customers.  Where has Holly been?  Where was Holly at the Citizens' Public Hearing back in May?  She received her own personal invitation, which she completely ignored.  Holly is useless fluff.

FirstEnergy's corporate counsel, Gary Jack, pretended all this information from his company is completely fascinating.  Like he hadn't had a hand in putting the excuses together?  The funniest part -- his studious concentration was repeated on the second day!

The company claims that meter readers “investigate” outages and standby until crews arrive.  Has anyone ever see this happen?  I've driven by plenty of downed wires over the past couple of years and NEVER saw a meter reader onsite.

FirstEnergy says it has added a floater position for meter reading to deal with life's little realities.  Is that one for each operating company?

FirstEnergy admits that in December, 28% of customers had back-to-back estimates.  Complaints peaked in April and June of this year, but their PowerPoint graph still showed complaint numbers higher than "normal."

FirstEnergy said it "can’t rest on its laurels."  What???  What "laurels" would those be?

FirstEnergy says it will evaluate additional criteria to flag estimates that need review before bills are sent.  But you can call in actual meter readings on months scheduled for estimated readings or enter actual readings using the companies’ website (because they don't intend to do their job?)

I would like to know how these monthly statistical reports to the PSC help customers?  The company missed readings for a whole bunch of invented reasons – when are they just going to man up and apologize?

I think the PSC got an earful.  Let's hope they will now take the initiative to regulate FirstEnergy.