"It is clear that the Alliance will seek to make this process unnecessarily burdensome and overly complicated before the board can even make its initial determination on whether the franchise should be granted," the company's lawyers conclude.

Clean Line does not object to the Alliance's limited intervention at this stage; however, Clean Line reserves the right to request specific limitations be placed on such participation depending upon the participation of other parties who may have the same interest as the Alliance. Such limitations may include but shall not be limited to prohibiting the Alliance from preparing direct testimony, submitting exhibits or other evidence, or conducting cross examination of witnesses. If the Alliance seeks to "advance the mutual arguments of all its members" as stated in its Petition to Intervene, limiting its participation to briefing legal arguments will satisfy the Alliance's goal.

...the motive of the Alliance is clear: to make sure Clean Line does not build this  transmission line. A recent statement
from the Alliance Board President Carolyn Sheridan to the Alliance members concisely details the strategy:
"From the Board President
Think about it: Imagine you're [Rock Island Clean Line ("RICL")] and you have to file all
this information about a parcel of land in a distant location: How much time would it take
you to learn the names and addresses of all persons with an ownership interest in the land?
How much work would it be for you to prepare a map showing the location of all electric
lines and supports within the proposed easement; and the location of and distance to any building w/in 1OOft. of the proposed line? A lot of work. Multiply that by hundreds; and
you have an idea of how important it is to the success of RICL's project that it obtains.
The more parcels upon which RICL has to do all this work, the less likely this project is to
succeed. Every parcel upon which it has to do all this work is one more shovel of dirt on
the grave of this RICL line. Join the opponents of the line. DO NOT sign an easemnts
[sic] with RICL.
Carolyn Sheridan
Board President"

Without bifurcation, it is clear that the Alliance will seek to make this process unnecessarily burdensome and overly complicated before the Board can even make its initial  determination on whether the Franchise should be granted.

The Alliance seeks to force Clean Line to waste time and resources, and consequently also the time and resources of the IUB, with the hope that Clean Line eventually gives
up on the project.

...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.

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.

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…

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.

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.

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.

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.

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.)

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.

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.