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FirstEnergy Charging Admission for Voters to Talk to Legislators

11/21/2013

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Well, isn't this cozy?

FirstEnergy is "sponsoring" a 2014 Legislative Outlook luncheon, and charging the people $15 a head to come talk to their elected officials.

Sort of lets you know who's in charge, doesn't it?  FirstEnergy pulls the strings and the legislators line up like trick ponies at the circus... a circus that you must pay to attend.
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Potomac Edison Says All Its Estimated Bills are Wrong, But That's Okay!

11/20/2013

4 Comments

 
I got my Potomac Edison bill yesterday.  I found out I'm not "special" because my bill was estimated.  But that's not the half of it.  My bill was overestimated by hundreds of kwh... again!  So I had to make a phone call to ask for a correct re-billing... again.

My Happy Town guide was overjoyed to do the grunt work of recalculating my bill and doing whatever it is he does to instigate a re-billing.  Aside from that, he was completely useless to provide any insight or assistance into the root problem that causes me to have to call and ask for a re-bill every other month, other than the suggestion that I read my own meter every other month and call it in before the estimated bill is calculated.

No. Just no.

He did admit that all Potomac Edison's estimated bills are wrong because it is based on last year's data that may be inaccurate.  But he thinks that's okay because it will all even out the next time Potomac Edison comes to read my meter and issues me a correct bill.

But I did ask how much they were paying him that it doesn't matter in his own household if his utility bills fluctuate hundreds of dollars every month.  Silence.  Does he realize that seniors and people just barely hanging on month-to-month are on budgets and can't afford these monthly fluctuations caused by the fact that Potomac Edison hasn't been doing its job?  More silence.

And then he had the audacity to ask if there was anything else he could do to "help" me.

Nope, this bi-monthly comedy routine makes me almost as giddy as a wagon full of puppies.  :-)
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PATH Failure Goes International

11/19/2013

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Patience and I met two very delightful new friends today.  Hyosil Kim, a reporter for Korean newspaper The Hankyoreh, and her translator Brian Kim, spent the day with us touring Jefferson County and learning about PATH's spectacular, flaming failure to get its transmission project sited and permitted.

PATH's failure is interesting to the people of South Korea because they are engaged in their own furious battle with transmission developer Kepco over a 765kV line intended to export nuclear power out of the country.

The concept of social justice is being debated in Korea, just as it is here.  Why should any person have to sacrifice their home and well-being to serve the energy or environmental needs of others?

We took a fond trip down memory lane with many of our fellow PATH opponents during our tour of PATH's proposed route, recalling funny and touching moments during our successful David v. Goliath struggle to take control of our own energy future.

You'll be happy to know that the story of The Coalition for Reliable Power is just as funny when translated into Korean!


The message Hyosil will take back to Korea is encouragement for the people to persevere and refuse to give up!

We'll be posting a link to Hyosil's story here when it's written...
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WV PSC Schedules Evidentiary Hearing on Potomac Edison/Mon Power Billing & Meter Reading Case

11/18/2013

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The WV PSC issued an Order today setting an evidentiary hearing for December 17 - 19 on its General Investigation into meter reading, billing and customer service practices.

An evidentiary hearing will allow interested parties to intervene, file testimony and cross examine witnesses.  At the end of the process, the PSC will order remedies, if it determines that any are necessary.

The Commission has set a deadline of November 27 for petitions to intervene in the case.

In addition, FirstEnergy filed its response to the PSC Staff's recommendations.

FirstEnergy is now admitting that maybe we're right.  It's the legal equivalent of being "a little pregnant," I suppose.
...the Companies identified accounts in the Potomac Edison and Mon Power territories that we deemed necessary for reading on a monthly basis through at least January 2014 in order to help address the situation. If the Companies are unable to obtain an actual    reading for those accounts during that period, the billing department is reviewing the history to manually determine an estimate.    If a manual estimate cannot be calculated or other problems are discovered, the account is escalated to a Meter Reading supervisor.
How do you suppose these accounts were "identified?"  In its monthly statistical filing, FirstEnergy states that there are only "several thousand" problem accounts (out of more than 500,000).  I guess that must mean I've heard from every one of those customers over the past year and a half because I'm sure they didn't leave out any of the people who've told me their billing horror story.
After last month's review of accounts with multiple estimates during last year's storms and winter heating season,  we have identified several thousand customer accounts for special handling. This is a proactive attempt to mitigate compounding issues from a year ago. These accounts will be downloaded for reading on a monthly basis starting November through January 2014.    These accounts also have a hold placed OR billing to first allow for an internal review if an actual read cannot be obtained.    The review includes a billing representative's analysis of last year's estimation through the winter heating period to manually determine an estimate.    If a manual estimate cannot be calculated or other problems are discovered the account is escalated to the Meter Reading supervisor for further handling.
So, are you "special?"  FirstEnergy still hasn't gotten it right.  We are ALL "special."

How much money is this company going to waste on uninspired, half-assed "fixes" and denial of the problem?  Will they end up spending MORE than it would have cost to just do it right in the first place?
2 Comments

PJM Market Monitor Transmogrification

11/15/2013

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I just had to click that link on my facebook feed yesterday.  After months of trying to ignore the PJM Market Monitor's State of the Market Reports because it's like being sucked into an alternative universe and it makes my brain hurt, I saw a link to this:
DOH!  It’s worth it just for this sentence:

"Markets do not automatically provide competitive and efficient outcomes."

Here it is, with the full all-in-one option or separate sections:

3Q PJM State of the Market Report Page

Here’s the full version: 2013 3Q PJM State of the Market Report

And the short version, oh, how I love it when this happens:

"The market design should permit market prices to reflect underlying supply and demand fundamentals. Significant factors that result in capacity market prices failing to reflect fundamentals should be addressed, including better LDA definitions, the effectiveness of the transmission interconnection queueprocess, the 2.5 percent reduction in demand that suppresses market prices, the continued inclusion of inferior demand side products that also suppress market prices and the role of imports."

Got that: … the 2.5 percent reduction in demand that suppresses market prices…

- 2.5%

Gee, sounds like we ought to pay to build some more power plants and transmission lines…
Okay, you got me, Carol.  I clicked.... and soon found myself poking through the entire multi-volume set and reaching for my Magic 8 Ball translator.

Here's where I went first:  Section 12, Planning

Blah, blah, generation queue, backbone transmission, blah, blah  *screech*
The goal of PJM market design should be to enhance competition and to ensure that competition is the driver for all the key elements of PJM markets. But transmission investments have not been fully incorporated into competitive markets. The construction of new transmission facilities has significant impacts on energy and capacity markets. But when generating units retire, there is no market mechanism in place that would require direct competition between transmission and generation to meet loads in that area. In addition, despite Order No. 1000, there is not yet a robust mechanism to permit competition among transmission developers to build transmission projects.4 The addition of a planned transmission project changes the parameters of the capacity auction for the area, changes the amount of capacity needed in the area, changes the capacity market supply and demand fundamentals in the area and effectively forestalls the ability of generation to compete. There is no mechanism to permit a direct comparison, let alone competition, between transmission and generation alternatives. There is no evaluation of whether the generation or transmission alternative is less costly or who bears the risks associated with each alternative. Creating such a mechanism should be a goal of PJM market design.
Well, hot damn!  Someone's been paying attention!  But wait... the following paragraph indicates that the MMU's "solution" may just tip the scales toward imported transmission:
The PJM queue evaluation process needs to be enhanced to ensure that barriers to competition are not created. There appears to be a substantial amount of non-viable MW in the queues, which increase interconnection costs for projects behind them. The MMU recommends the establishment of a PJM review process to ensure that projects are removed from the queue, if they are not viable.
Perhaps this plan is intended to clear the way for viable generation in the queue to come online, but maybe its actually clearing the way for merchant transmission from other regions, which acts as a generator at the interconnection point.

Big, mean frowny face!  And he's serious, after helping to kill new generation in Maryland and New Jersey?  So, let's go back to Carol's favorite quote:  "Markets do not automatically provide competitive and efficient outcomes."  That's right!  Because we need a "market monitor" to artificially adjust the markets to fit a pre-determined pecuniary outcome.

And the next little point to ponder comes here:  Section 8, Environmental and Renewables.

Most interesting are the graphs near the end showing real time wind and solar generation by month.  The graphs show that wind generation peaks late at night in winter months, when we don't need it.  Solar, on the other hand, peaks in the middle of the day during the hottest months of the year.

I'm not even going to bother to search for the MMU's recommendation on that because it probably urges us to build more transmission lines to import wind for summer peak, instead of what would be logically obvious to a normal person -- to take advantage of on-site solar resources to reduce peak usage.  How many roofs could we cover with solar panels for the cost of just one of these "clean" transmission line monsters?  And why are the people who are supposedly served by all this market monitoring mumbo-jumbo disenfranchised from having any say in their own energy future?
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Potomac Edison & Mon Power Billing Tutorial

11/12/2013

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Do the people at FirstEnergy ever have an original idea?  Or do they run their company based mostly on ideas they find on my blogs?  If that's the case, I suggest that FirstEnergy self report its transgressions to every jurisdictional regulatory agency and try to make amends for all the funny accounting and other dishonest ways it has made money off the backs of struggling electric consumers.

I didn't go out looking to take issue with FirstEnergy's billing scam.  In fact, I tried to ignore it, or find someone else who wanted to lead the charge, for nearly a year before I just gave up and added it to an already rather full plate of power company shenanigans.  I don't call or email people asking them to take issue with what FirstEnergy does to its customers.  But when people contact me about how FirstEnergy has hurt them, I will listen and try to help them to the best of my ability.  FirstEnergy ought to try it... an honest effort to help people.

So, tonight a friend messages me to tell me he got a "billing tutorial" in his electric bill.  This isn't a surprise.  I've been waiting for it ever since we announced community meetings with an electric billing tutorial presentation.  I knew that would drive my FirstEnergy friends crazy.  Kind of like locking them in a round room and telling them there's a penny in the corner.  But, really, I expected them to cobble something together before the PSC public comment hearings.  Don't you think FirstEnergy's billing tutorial should have been an appropriate part of the company's presentation at the hearings?  Customers might have found it useful, at least more useful than that sorry litany of excuses they got instead.

Because I expected FirstEnergy to be a little copy cat, I purposefully did not put our tutorial online until after the public comment hearings.  No matter, FirstEnergy managed to download it as soon as it was available and combine it with other advice we had for their customers to pretend it was all their idea.  What a bunch of posers!

So, how did FirstEnergy do with their tutorial?  Do you know what your electric rate is and how it is calculated to arrive at the amount you must pay?  No, it's just more confusing crap that does nothing to create customer understanding.
From Meters to the Mailroom
A lot of effort goes into creating your monthly bill, and our goal is to make it as accurate and easy to understand as possible.  From meter reading to the mailroom, everything needs to operate effectively to deliver your bill.
The process begins with our meter readers who attempt to read your meter every other month. On the months that your meter is not read, your bill is estimated, which typically is based on daily usage from the same period during the prior year. Any difference between your estimated usage and actual usage is automatically adjusted the next time your meter is read.
After the reading is obtained, it is entered into our computer system, which compares your reading with previous readings. If it is outside of the expected usage, the reading is flagged for closer examination by our Customer Accounting associates. Inaccurate estimated readings either are adjusted, or we obtain another reading. Finally, the bill is calculated and sent to you.
We provide electricity to millions of customers and strive to deliver accurate bills every month. However, if you feel you’ve received a bill that is not accurate, you can read your meter and compare that reading with the one on your bill. For more information, visit www.firstenergycorp.com/aboutyourbill, or call our customer contact center – Monday through Friday from 8 a.m. to 6 p.m.
FirstEnergy's goal is to make your bill accurate and understandable?  In that case, they get a big FAIL.  If they had been meeting their goal, there would have been no need for my billing tutorial.  FirstEnergy "attempts" to read your meter every other month.  In that case, should we all "attempt" to pay them every month?  Your estimated bill is based on your usage from the same period last year, when the company failed to read your meter.  This means that your usage from last year is inaccurate.  You know what happens when you estimate based on inaccurate data?  The estimate is inaccurate, of course!  If FirstEnergy is flagging bills "outside of the expected usage" and the expected usage is inaccurate, then that means they will only flag a bill that is accurate?  This does not prevent an inaccurate bill from being sent to you.  FirstEnergy calculates your bill -- in some mysterious way that you don't understand and can't replicate at home.  You have no idea how your bill is calculated and FirstEnergy isn't going to tell you in their billing tutorial.  You're just supposed to trust that their "calculation" is correct?

But, if your bill is not accurate, you should do what I've been advising you to do with every estimated bill you've received for the last several months -- go read your own meter and compare it to the amount billed.  FirstEnergy's tutorial stops here.  What are people supposed to do after they read their meter and compare it to their inaccurate bill, FirstEnergy?  Just go ahead and pay it?  The rest of my advice tells the customer to call FirstEnergy and ask for an accurate re-billing when they discover a discrepancy.

FirstEnergy's meter reading tutorial is even worse.  Not only is it bogged down with unneeded, tedious detail, it provides senseless instruction that a meter must be read from right to left.  Why?  Won't the numbers be the same if read from left to right?  It's not like a math problem where numbers are carried over from one dial to the next.  It's a number. Instead of encouraging customers to read their meters, FirstEnergy's explanation only confuses them further.

Some days it's harder than normal to resist the urge to post completely bogus information on my blog just to see it blow up in FirstEnergy's face when they attempt to use it.  Instead, I amuse myself thinking about a gigantic corporation making decisions based on my blog. Idiots.
2 Comments

FirstEnergy & American Electric Power Transmission "Reliability" Ratepayer Shakedown

11/12/2013

4 Comments

 
Building transmission (whether it's needed or not) has been a utility profit center for years.  But now investor owned utilities are really shaking the transmission money tree to make up for the fact that the rest of their business is failing.

And like all good utility money-making schemes, West Virginia's out-of-state utility tedious twins go head-to-head to see which one can make the most money doing it fastest and "bestest."

Last week, FirstEnergy's Tony the Trickster made some big deal about a new transmission money making scheme approved by FirstEnergy's Board of Bamboozlers.  This $2.8B "transmission spend" was given cover by being dubbed the "Transmission Reliability Excellence Plan 2014-2017," like it's all about reliability and not about "target[ing] annual transmission Net Income growth of 20+%."  At what point do the reliability needs of customers intersect with FirstEnergy's need to make money?  Wow, serendipity!  FirstEnergy's system is going to be as "unreliable" as needed to grow income 20+%.  The more "unreliable" FirstEnergy's system is, the more money FirstEnergy makes!
The "near term" plan consists mainly of rebuilds and upgrades to FirstEnergy's ATSI and TrAILCo systems.  FirstEnergy will concentrate on its 69 & 138kV systems in order to avoid regulatory or community opposition hurdles that could slow down the "investment."  FirstEnergy also reasons that an improved system will cut down on future maintenance costs, and that will help keep O&M in check.

But, wait a tick, how much of this "need" for re-building has been caused by FirstEnergy's long-term failure to maintain its system, and therefore should properly fall under the category of ordinary maintenance expense that the company has already been reimbursed for?  If it were this easy, utilities could simply refuse to perform any maintenance on their transmission systems, and then wrap all the ordinary course repairs into some fancy package called a "Transmission Reliability Excellence Plan" and get reimbursed for it separately (and at higher rates) when a need to grow income arises.  This isn't "reliability," it's a ratepayer shakedown.  If FirstEnergy gets away with it, the company plans to increase their "reliability" to the tune of $12B "over time."

FirstEnergy reasons:  The majority of these projects located in the ATSI region will target 69kV lines, which are outside of the RTEP approval process, and that construction would occur on land where most rights- of-way are already secured.  But, assets assigned to TrAILCo must receive PJM RTEP approval and operate at 100kV and above, therefore these will be secondary to the low-hanging fruit in ATSI.

You'll be happy to know that public-money-sucker Burns & McDonnell has been hired to manage the engineering, procurement, construction and completion of the capital portfolio created for the plan and has established an office in Akron, OH
.  It's full steam ahead to spend as much of your money as fast as possible, little ratepayer!

FirstEnergy plans to put all its "transmission spend" eggs into its FERC jurisdictional formula rate baskets -- ATSI with a return of 12.4%, and TrAILCo, with a return of 11.7% for non-TrAIL projects and 12.7% for rebuilds and upgrades to the two-year old TrAIL line.

Is this really about "energizing the future by improving the health, capacity, and reliability of the transmission system for existing and new customer loads," or is it more about "energizing the future by improving the health, capacity, and reliability of the FirstEnergy balance sheet for existing and new shareholders"?

Meanwhile, not to be outdone, AEP has also announced its own plan to spend around $5B on the "reliability" of its transmission systems over the next 3 years.
AEP CEO Nick Akins said the company’s infrastructure investments will be aimed at improving the reliability of electric service to customers. He said the company expects to invest nearly $5 billion in its AEP Transmission Holding Co. unit through 2016, adding the holding company’s contribution to earnings will nearly double in 2014 alone.
However, AEP isn't afraid to invest in joint ventures and big, new projects outside its footprint. 

Both companies have also submitted numerous bids on the first two PJM transmission project bidding windows.


Which transmission investment business plan will be the winner?  And how much is this going to cost us before regulators catch on to the "reliability" scam and challenge it?  And what if someone goes after the companies' FERC ROEs?  The fun is only just beginning...

Maybe we should distract their attention by challenging these two companies to see which one of them gets into the solar business first?  How much money is there to be made putting solar on every residential roof and then charging the customers "rent" for the investment?  Or will they continue pumping the transmission "reliability" well until it runs dry before taking any positive action to make themselves relevant in a brave, new, distributed generation world? 
4 Comments

All It Takes Is One Squirrel To Bring Down the Grid

11/8/2013

2 Comments

 
by Dr. Luis Contreras
The US Power Grid is a very complex system, expensive, insecure and not very reliable, as we found out yesterday in Rogers and NWA where thousands of people were left in the dark while SWEPCO tried to fix the grid. All is good now, but it could happen again, say tomorrow.

Fossil fueled power plants, many of them coal-fired, are based on the 1800’s idea of using fire to heat up water and make steam to power generators, a technology that goes back to the Industrial Revolution of 1712.

Central bulk power is located far away from people to hide the air pollution and water contamination, based on the idea “if you don’t see it or can’t smell it, we can live with it.” Coal plants are built near rivers and lakes as they use great quantities of water to generate steam. The man-made SWEPCO 500-acre lake is warm 365 days a year because it serves as a cooling agent for the Flint Creek Power Plant. The water is between 70 and 90 degrees Fahrenheit, good for fishing if you don’t mind the emissions of sulfur dioxide, nitrogen oxide, mercury and other hazardous pollutants.

Bulk power is transmitted on the Grid where different voltage levels are interconnected by substations which contain voltage transformers, circuit breakers, surge arrestors, isolators, as well as measurement equipment and switchgear.

Electrical Engineers spend years designing and planning trying against all odds to make it work under any conditions. It is not easy and it is not even possible: adding redundancy only increases cost and complexity, any additional component can make it fail. Even Rocky, the Flying Squirrel can take it down.

The lean alternative is distributed generation and consumption, using the existing grid as a buffer: extra energy generated is sold to the Grid which sells energy to everyone else. That is true reliability. To take down a distributed power system, you need millions of squirrels, at least one per home. Squirrels and humans can live in peace, as long as we don’t put all of our eggs in one Grid. Maintaining the existing grid and distributed renewable power are the future of the Ozarks, not more 345,000 Volt transmission lines.

Doc is a a Lean Systems Expert Consultant, with a PhD from Georgia Tech, trained by Jesuits to take a firm stand on defense of social justice, and protect his family and friends "Por los demas, y para los demas, con hambre y sed de justicia."

He is an Austin TX resident, with a vacation home in Eureka Springs Arkansas.

He was trained in Martial Arts to respect others and have a lead and take action with a calm mind and determination.

When in doubt, he asks himself "what would Bugs Bunny do?" that helps him think out of the box, take a chance, and hope for the best.

He feels that we are here for a reason, we will be gone soon, and we need to make a difference in what matters - good friends, mother earth, our common house, are important to him.

He plans to make a $100 contribution to the Save the Squirrels Foundation.


2 Comments

WV PSC Staff Agrees With Consumers on Potomac Edison/Mon Power Problems

11/8/2013

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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.
According to the MP and PE response dated October 14,2013 to Commission Question No. 3 both MP and PE currently employ more than the number of budgeted meter readers.    Based on an informal meeting on October 10, 20 13 between Staff and MP and PE some of the above budgeted meter readers are “floaters” or “rovers” used to address both planned and unplanned meter reader absences. During the October 1Oth meeting it was confirmed that since April 2012
full time and contract meter readers are required to use personal vehicles which, according to the utilities are subject to monthly inspections.    While not necessarily an unreasonable practice Staff has concerns that requiring meter readers to use personal vehicles may bias the utilities’ determination of which customers are annual read customers using stated criteria of remote access and or safety where for example “Safety is defined as anything that may pose a hazard to the meter reader or his/her vehicle.” (FirstEnergy Supplemental Response dated 8/30/13, Emphasis Added.)
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.
Mr. Fletcher notes the Companies have not provided answers to question 7 from the Commission: “The number of complaints handled by the customer contact center with a breakdown by complaint type.” The Companies have responded that the tracking of complaints is not done through a customer contact. The only information supplied in answer to this request is a regurgitation of the formal and informal complaints filed before the Commission. Mr. Fletcher states Electric Rule 2.1.a requires utilities to maintain the records required by the Electric Rules and Electric Rule 5.5 requires the utilities to keep detailed records of adjustments t o customer accounts and detailed records of high bill complaints. It appears to Mr. Fletcher the Companies have not been in compliance with these sections of the Electric Rules.
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.
Staff remains concerned about the prospects for an increase in MP and PE complaints during the forthcoming winter heating  season.    The October 14thmonthly report states no changes have been made to the estimation routine “this month” pending completion of EPRI’s review. Staff notes that some changes have been made to the estimation routines based on the FirstEnergy response dated August 2,2013 to Staffs Second Data Request Question No. 3.    Staffs review of numerous billing and usage histories associated with complaints received by the Commission show the majority of such  histories for individual complainants contain numerous months from the summer of 20 12 through the summer of 20 13 with “bad” data.    “Bad” in that several consecutive low estimated monthly usages are followed by a month with significantly large “true up’’ actual usage.    The large “true up” actual then tends to bias upwards the subsequent estimates.    These trends were illustrated by Attachment 3 to Staffs July 15thInitial Memorandum and Staff has subsequently observed the repetition of those trends many times. Consequently, regardless of how theoretically sound the estimation routines are or might be improved to be, Staff is concerned that “bad” data generated in 2012-2013 will produce unreliable future estimate usages for the same customers.
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.
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A Circus of Unprofessionalism:  Kansas Corporation Commission Approves Grain Belt Express

11/8/2013

7 Comments

 
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.
In Kansas, the project is estimated to result in 2,340 jobs annually during the three-year construction period, and an estimated 135 jobs to operate and maintain the project on an ongoing basis. Additionally, construction of the associated wind facilities in Kansas is estimated to generate between 15,542 and 19,656 Kansas jobs, while operating and maintaining the wind farms is expected to generate 528 Kansas jobs.
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:
However, there was no competing
evidence in the record to suggest that consumers would not benefit in some manner.
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:
BENEFITS TO CONSUMERS INSIDE AND  OUTSIDE OF KANSAS

Grain Belt's Executive Vice President of Strategy and Finance, David Barry, sponsored a study of the benefits of the project to consumers in and outside of Kansas. The general approach taken was to develop a simulation model of electric demand in the MISO and PJM states, to make assumptions about future demand in those states in 2019, and to simulate how the sale of Kansas wind energy into these markets would affect aggregate electric generation costs (which drive the prices consumers pay) and emissions levels of various pollutants (which affect health). Four future scenarios were assumed for the analysis:

Business As Usual - Energy demand grows under a moderate economic recovery with no
major changes to existing environmental policy, generating technologies, fuel  commodity prices, or other key energy market assumptions.
Slow Growth - Continuation of depressed economic conditions characterized by slow demand growth, continued low fuel commodity prices, and minimal  transmission/generation expansion.
Robust Economy - Strong recovery in economic activity characterized by accelerated growth in electrical demand, higher fuel prices and emission allowances prices, and increased
activity in new generation and transmission projects.
Green Economy - Expansion in environmental policy including carbon regulation and a
federal renewable portfolio standard under robust economic conditions including high
demand growth, an increase in fuel prices, and increased activity in new generation and transmission projects.

Using PRODMOD software, the impacts of selling Kansas wind energy into the PJM and
MISO markets were simulated and the following results were reported:

Thus, Grain Belt's analysis of consumer  benefits is that consumers-largely in the PJM
and MISO states-benefit by reducing the cost of electric power ranging between $354 million annually to $546 million annually depending on the assumption one makes about demand levels in 2019. Grain Belt also asserts that consumers also benefit by reductions in emissions levels.
The Commission is not an environmental regulator and estimating the economic  benefits with any precision based on assumptions six years from now over many states included in the PJM and MISO footprints seems questionable to me. However, there was no competing evidence in the record to suggest that consumers would not benefit in some manner. Certainly, the simulation model does provide some indication of the range and magnitude of benefits. At a conceptual level, Grain Belt does not have the power to force anyone to purchase its power. Thus, if utilities in the MISO and PJM markets purchase power from Grain Belt, they must believe that the purchase makes them better off in some manner--either by reducing emissions mandates, meeting a state renewable portfolio standard, or reducing costs. In my view, if there is a viable market for Kansas wind energy in eastern states-the business premise
upon which this project is based - then there must be some benefit to be gained in eastern states.
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...
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    About the Author

    Keryn Newman blogs here at StopPATH WV about energy issues, transmission policy, misguided regulation, our greedy energy companies and their corporate spin.
    In 2008, AEP & Allegheny Energy's PATH joint venture used their transmission line routing etch-a-sketch to draw a 765kV line across the street from her house. Oooops! And the rest is history.

    About
    StopPATH Blog

    StopPATH Blog began as a forum for information and opinion about the PATH transmission project.  The PATH project was abandoned in 2012, however, this blog was not.

    StopPATH Blog continues to bring you energy policy news and opinion from a consumer's point of view.  If it's sometimes snarky and oftentimes irreverent, just remember that the truth isn't pretty.  People come here because they want the truth, instead of the usual dreadful lies this industry continues to tell itself.  If you keep reading, I'll keep writing.


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