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Testimony Filed in PATH's Abandonment/Formal Challenges Case at FERC

11/24/2014

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Friday marked the first time the public has been able to take a look at what's shaken out of PATH's consolidated FERC case (ER09-1256-002 & ER12-2708-003).

Docket No. ER09-1256 deals with the three Formal Challenges to PATH's formula rate filings for rate years 2009, 2010 and 2011 that were made by West Virginia ratepayers Keryn Newman and Alison Haverty.  The Challenges alleged that PATH recovered millions of dollars that it was not entitled to.

Docket No. ER12-2708 deals with PATH's recovery of $121M of stranded capital investment in the PATH project.  In 2008, FERC granted PATH the right to recover all prudently-incurred expenses for the project in the event it was abandoned for reasons beyond PATH's control.

These two very different PATH cases were consolidated by FERC in 2012, forever joined at the hip for settlement and hearing purposes.

Earlier this year, the settlement phase ended and a procedural schedule for hearing was set.  Under the procedural schedule, PATH filed its Initial Direct Testimony in May of this year, supplemented in July.  Intervenors filed their Direct and Answering Testimony on Friday.  The public, trial-type evidentiary hearing is scheduled to begin on March 24, 2015 in Washington, D.C.

Here's what was filed Friday:

Direct and Answering Testimony of Keryn Newman and Alison Haverty, along with testimony from their witness Doug Kaplan.  Files are labeled, and the narratives are files number 2 of 20, 16 of 20, and 17 or 20.  The other files are supporting exhibits as mentioned in the testimony.  This testimony deals exclusively with the Formal Challenges in Docket No. ER09-1256.

Testimony and Exhibits of FERC Trial Staff.  Witnesses Miller and Deters deal with the Formal Challenges, while witness Keyton testifies on PATH's return on equity percentage that is part of the abandonment docket.

State Agencies and Joint Consumer Advocates filed testimony.  The testimony of witness Lanzalotta is with regards to the amount PATH should recover in the abandonment docket, while witness Woolridge deals with PATH's return on equity in the same docket.  The third JCA witness questions the prudence of PATH's legal expenses.
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Settlement Proposal Filed in FirstEnergy WV Rate Case

11/3/2014

1 Comment

 
A settlement proposal was made public today by parties to the West Virginia Mon Power/Potomac Edison base rate case.

The settlement must be approved by the WV PSC before it becomes final.  The PSC has scheduled a hearing on the settlement for Nov. 7 at 9:30.  You can watch the webcast here.

The settlement was crafted during negotiations between the company, the staff of the PSC, the Consumer Advocate Division, WalMart and the WV Energy Users Group (a group of energy hog industrials).  The PSC Commissioners (what few we have left) did not have a hand in crafting this settlement.  They will have a hand (or a rubber stamp) in approving it.

So, what happened?  They agreed to a rate increase effective Feb. 25, 2015.  The press release yammers on about how much this will cost the "average" customer (23 cents per day, $6.90 per month, $84.40 per year).  Mr. & Mrs. Average Customer use exactly 1,000 kwh of electricity every month.  Your usage isn't so neat, so therefore your increase will vary. 

But, it's not the rate increase the company asked for.  It's less.  The original proposal was going to increase Mr. & Mrs. Average Customer's bill something like $15/month, so consider the proposed settlement to be slightly less than half the amount requested.

The company had asked for a total of $151M annual increase.  The settlement amount is $62.5M annually.  This amount includes a $15M (1.45%) increase in base rates and a new $47.5M surcharge for vegetation management. 

The vegetation management surcharge bears further examination considering the company asked for a $48.4M surcharge for increased vegetation management.  The company has been receiving a separate amount for vegetation management that has been included in the base rate for years ($28M).  What this settlement does is remove that amount from the rate base and combine it with an additional amount for increased vegetation management to create the new vegetation management surcharge.  This new surcharge is subject to filings in the first, third and fifth year in which the company must true up actual expenditures to the amount collected.  Gone are the days of FirstEnergy collecting millions for "vegetation management" that it never performs (and contributes to more severe and prolonged storm outages).  Now you'll actually get the vegetation management you pay for!

Back to the base rate increase:  Included is $46M of 2012 storm costs, amortized over a 5-year period, without earning a return (about $9M/year).  Once the 5 years is up, this is gone forever (unless we have another storm disaster in the meantime). 

The stipulation regarding the $60M FirstEnergy wanted to collect for closed power plants Albright, Rivesville and Willow Island sounds like Yoda wrote it.
For the unrecovered the companies may account, undepreciated investment.  
Balances in the 2012 deactivated power plants (albright, rivesville, and willow.  
Island) in any manner the companies deem appropriate, with gaap in accordance.  
And regulatory accounting.  Not, the parties agree that such accounting does.  
To recover these costs or amortization expenses in future rate establish a right.  
Proceedings, and this joint stipulation shall prevent the parties from nothing in.  
To recovery of these taking whatever position they deem appropriate in relation.  
Amounts in future proceedings.  Herh herh herh.
I'm not sure what it means.  Probably nobody else knows either.  Except maybe Yoda.

The companies must increase the amount they contribute to the Dollar Energy Fund that assists low income folks with their outrageous FirstEnergy electric bills.  FirstEnergy's increase is $150,000/year.  In addition, the company must continue to "contribute" an additional $250,000/year that they recover from ratepayers.  So, essentially, YOU are paying this extra and FirstEnergy is getting the credit for the "donation."  Isn't that special?  Betcha' didn't know that FirstEnergy provided charitable giving coordination services like that!  Of course, how much of any of this is "giving," when all the money ends up right back in FirstEnergy's pocket?

This one is kinda confusing.  Even Yoda can't help. 
The proposed increase to the customer charge for residential and small commercial
customers shall remain at $5.00 per month.
The increase shall remain at $5.00 per month?  We're already paying $5.00 per month.  Does this mean that we're now going to pay $10.00 per month, or does this mean that there will be no increase in this fee?  Clarity needed.

The company is allowed to establish a regulatory asset for its expected EPA compliance plans at Harrison and Ft. Martin.  This amount will be deferred (sit on the balance sheet uncollected and earning interest) until a future rate case
.

The company will earn a 9.9% ROE, down from the requested 11%.  When combined with the return on debt of 5.15%, and adjusted by the company's capital/debt ratio, the total return will be 7.36%
.

The company will receive an additional $1,074,174
per year to read every meter every month going forward.  This is down from FirstEnergy's requested $7.5M yearly cost to read meters monthly. Now the trick is going to be making sure the company actually DOES the required readings!  No skimping now, we'll be watching!

So, what do you think?  Did your advocate cut you a good deal in this rate case?  You can submit comments to the PSC here.


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The More Things Change, The More They Stay The Same

11/2/2014

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It has been my pleasure to work with Dr. Luther Gerlach a couple of times over the past few years as he continues his studies of transmission line opposition groups.  Dr. Gerlach is professor emeritus of anthropology at the University of Minnesota, and has been studying transmission opposition since the 1970s. 

In 2013, Luther updated his encyclopedia article, Public Reaction to Transmission Lines  (EEI has made the article publicly available for download here).  After it was published in 2014, the Edison Electric Institute invited him to present at their recent Utility Siting Workshop.  I again participated in discussions with Luther over several months as he put together his presentation for the workshop, Transmission Lines: Characteristics and Effects of Opposition.

Discussion with Luther has a way of making you think!  During the most recent discussions, Luther shared with me a film he narrated in the 1990s from footage he had acquired during the CU power line fight in Minnesota in the 1970s.  This battle was the subject of Paul Wellstone's book, Powerline: The First Battle of America's Energy War, which is sort of a transmission opposition primer.  A lot of us have read it to analyze what went wrong with their fight so we can improve on our own.  If you haven't read it yet, go get a copy!

I downloaded Luther's film, Grassroots Energy, and settled in to watched it by myself. 

Then I invited a fellow transmission opponent over to watch it with me a second time so we could discuss the similarities to our own fight.

Then, with Luther's permission, I shared it with a few other transmission opposition leaders across the country.

Now, I can share it here... Download and watch this film!  For even more fun, watch it with your transmission opposition buddies and plan a discussion afterwards.

Although it's been 40 years since the CU battle, I was struck by how much we're still reacting to new transmission proposals with the same emotions and actions that formed these opposition groups many years ago.  We still share information with others, and we still try to find better solutions. 

Now I'm going to go watch it again... while waiting for better solutions!
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And the History Book Says...

11/2/2014

9 Comments

 
It's been a long time since I last got a google news alert for "Potomac-Appalachian Transmission Highline."  So long, in fact, I'd forgotten I even had those search terms set to notify.  But, just in time for Halloween, the PATH zombie reared its ugly head and I got a notice last week that some right-wing think tank had published a paper where those terms were mentioned, America’s Electricity Grid: Outdated or Underrated?
And what did the author have to say about PATH, more than three years after its death?  How has history treated this stunningly costly failure of "independent" planning?
Despite identification of areas in which transmission capacity is limited, a “not in my backyard” (or anyone else’s, in some cases) attitude toward new transmission line siting has resulted in cancellation or delay of some new transmission lines.

For example, in 2011, PJM cancelled the proposed Potomac Appalachian Transmission Highline (PATH) project, a 275-mile transmission line that would have run through West Virginia, Virginia, and Maryland to deliver electricity into Northern Virginia. Although the line was designed to improve reliability in eastern PJM, changing forecasts of electricity demand growth and intense opposition to siting the line led to the project’s cancellation.
It's the opposition that will be remembered, not individual analyses and the fine line that supposedly determined this white elephant was needed.

Hey, remember this?  PATH's talking heads insisted that opposition had nothing to do with PATH's cancellation.

But, history says it did.

While the article's conclusions are pretty screwed up, it does a nice job explaining the bulk power system and federal regulation thereof.  It's a good "backgrounder" for folks new to the transmission world.  Think about how much more reliable our system would be though, if we brought back the "islands" of the past and operated them as smaller parts of the bigger system (aka "microgrids").
Beginning in the late 1920s, electric utilities began to integrate their operations to improve reliability and reduce costs. Previously, utilities had operated as “islands,” meeting the demand for electricity solely from their own generating plants. To ensure reliable service, this meant building extra generating capacity to keep in reserve, in case unexpected problems caused their plants to shut down.[2] By integrating their operations, utilities could provide more reliable service without building as much backup generating capacity. In essence, if a generating plant at Utility A suffered a forced outage, one of Utility B’s generators would be available to ensure the lights stayed on. The concept is similar to diversifying a financial portfolio. Instead of investing everything into just one company’s stock, buying multiple stocks, bonds, and other investments reduces the risk of a sudden financial loss.
Microgrids that can be islanded from the larger system at times when the larger system fails (remember Superstorm Sandy?) can continue to provide power for necessary services.  And if microgrid "A" suffers a forced outage, it can borrow from microgrid "B", or "C," or "D," or any other nearby microgrid.  Relying on just a handful of generators and long-distance transmission lines creates parasitic load pockets with no native generation.  Those folks have nowhere to turn in case of emergency.

Building more transmission lines isn't the answer.  The answer is a more democratic electric grid system that benefits consumers and local communities, not gigantic, investor-owned utility holding companies.
9 Comments

Settlement in Progress in Potomac Edison/Mon Power Rate Case

10/27/2014

7 Comments

 
If you were looking forward to watching the PSC evidentiary hearing via the Commission's webcast like I mentioned on the radio last week, change of plans.

There won't be an evidentiary hearing. 

As I also mentioned, there will be a rate increase.  It's only a matter of how much.  The Staff of the Public Service Commission, your Consumer Advocate, Wal-Mart and the Energy Users Group have reached a settlement with FirstEnergy "in principle."  The exact amount of our rate increase is still under wraps.

If FirstEnergy is settling, it probably means us ratepayers are gong to take it in the... wallet.
7 Comments

Bad Estimate Fever Is Spreading

10/27/2014

5 Comments

 
An Indiana utility is apologizing to its customers after failing to read electric meters for months, then issuing gigantic "catch up" bills when finally performing an actual meter read.

Remind you of anyone?

Vectren's excuse is that its meter reading contractor simply quit reading meters at the end of its contract period when it knew it would not be receiving a new contract.  The company says that the 400 customers affected can pay their gigantic bills in smaller increments, without interest.

The company has "put a formal communications plan in place."  This means they're spinning and trying to downplay the true magnitude of the problem.

The Courier Press says the problem is much bigger than Vectren has admitted.
The Courier & Press began investigating this issue after receiving a call from a local business owner on Friday concerned that her bill had tripled without warning.

Vectren initially said that more bills than usual were estimated over the summer because the company switched meter reading contractors, and it was changing the readers’ routes.

“Without getting into specifics, there are challenges that happen with any contractor transitions,” Hedde said Tuesday morning. She added that the anonymous caller’s high bill was likely atypical.

“I don’t want to give the impression that that is normal,” Hedde said. “She is experiencing something hopefully that is an anomaly.”

But response to a Courier & Press’ Facebook post showed the issue was widespread. Hundreds of people replied to the post with stories of bills that were several times what they expected.
The Courier & Press characterizes the problem as affecting "thousands" of customers.

The Indiana Regulatory Commission doesn't seem to see this as a problem.
But mistake or no, customers whose bills were underestimated must pay up, said the Indiana Utility Regulatory Commission.

“They are responsible for it,” said Natalie Derrickson, a spokeswoman for the Indiana Utility Regulatory Commission. “At this point, if a customer feels like their bill was estimated and they have larger bills than they were expecting, their first step should be to contact Vectren. If the customer feels like the issue is not resolved, they should contact us.”
This utility failure probably couldn't come at a worse time of year for struggling families.  No Christmas this year, kiddies, Mommy & Daddy have to pay the electric bill instead!

Seems to me that if the problem was caused by a contractor that did not live up to its legal obligations, then Vectren and/or the affected customers have a clear course of action.  Unless... maybe Vectren isn't being honest about this and is scapegoating a contractor they no longer do business with?

You'd think the Indiana Regulatory Commission would at least want to get to the bottom of this.

At any rate, the Courier & Press wants to know what the people think -- Should utilities be permitted to estimate customers’ bills for periods longer than one month?

As we found out here in West Virginia when thousands of customers were abused in exactly the same fashion by FirstEnergy, meters should be read every month.
5 Comments

Don't Let FirstEnergy and Other Corporations Buy Your Vote!

10/27/2014

2 Comments

 
I don't know about you, but I've had my fill of election season annoyances.  The commercials, phone calls, mailings, and facebook accusations can stop now.... I've already voted.

I hope you do a little research on the candidates before you vote!  Campaign finance reports are a good place to start:
Ohio-based FirstEnergy has been a busy little bee supporting certain candidates for state offices.  But some candidates didn't take FirstEnergy's dirty money.

In the 16th District Senate race, Senator John Unger hasn't received any FirstEnergy money.  However, his opponent, Larry Faircloth took $1000 from FirstEnergy's PAC.  Faircloth also took money from Roach Oil (that benefits from high eastern panhandle gas prices). Campaign finance aside, Faircloth is also responsible for the 35% hike in Berkeley Co. sewer fees.  Developer Faircloth filed a lawsuit seeking to invalidate developer impact fees for increases to sewage capacity.  Due to loss of the impact fees, the sewer district had to file for an 11% rate increase.  Larry Faircloth's personal financial interests seem to trump the interests of the citizens he wants to represent.  I have reservations about whose interests Faircloth would serve if elected.

In the 67th District Delegate race, Delegate Stephen Skinner's campaign finance reports are FirstEnergy-free.  That's not too surprising, since Delegate Skinner has taken an active role in criticizing FirstEnergy's bungling of estimated bills and recent rate increase request.  His opponent, Pat Rucker, lists a $500 contribution from FirstEnergy PAC on her campaign finance report.  Which candidate do you think would do more to protect you from FirstEnergy's money-grubbing, shoddy business practices?  I didn't see Pat Rucker at the recent FirstEnergy rate increase hearings.  She must support the company's request for a 17.2% hike in your electric bill.

In the 66th District Delegate race, Mountain Party candidate Danny Lutz has received no funding from FirstEnergy.  However, his opponent, Frontier's representative Paul Espinosa seems to be pretty cozy with the FirstEnergy bigwigs in Akron.  In addition to the obligatory $1,000 donation from the FirstEnergy PAC, FirstEnergy's boy also got another $1,000 donation from FirstEnergy CEO Tony Alexander.  You'd think the Alexander family would have better things to do with their money than to toss it away on a West Virginia Delegate's race?

A vote for Unger, Skinner or Lutz is a vote AGAINST FirstEnergy!  Don't forget to make yours count!

2 Comments

Cheers and Jeers for DOE's Draft Congestion Study

10/25/2014

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Section 1221 of the Energy Policy Act of 2005 directed the U.S. Department of Energy to complete a transmission "congestion study" every three years.  The congestion study is supposed to lead to designation of "National Interest Electric Transmission Corridors" (NIETCs).  A transmission project sited in a NIETC is subject to "backstop" permitting authority by FERC if a state fails to act on a permit application within one year, or lacks authority to issue a permit.  It's a three-step process to federal electric transmission siting and permitting that should NEVER be allowed to happen.

DOE's initial attempts ran into a buzzsaw of opposition that ended up in two separate federal court decisions that effectively castrated Sec. 1221.  But, hey, that Sec. 1221 mandate still exists, so DOE must still go through the motions.

And that's what they did, albeit 2 years past the 2012 due date. The DOE secretly opened their "draft" congestion study up for public comment (never mind the contradiction of a secret opportunity for public comment, we won't dwell there). 

The public commented -- nearly 100 comments panning the report and warning against designation of any new NIETCs were submitted by interested "stakeholders."

But, a handful of industry players also found out about the secret study and submitted comments.  So, let's take a look!

Utilities SDG&E, Southern Co., Duke, and Florida Municipal Power Agency filed self-serving comments about their own service territory, either pointing to "congestion" where they want to build lines, or cheering a DOE finding that there was no congestion in their region.

Regional transmission organizations Southwest Power Pool, NY-ISO and ISO-NE
also filed comments.  The general gist of their comments was that RTOs already have robust transmission planning processes and power markets that make DOE's congestion study a frivolous and unnecessary duplication of effort.  And then they resorted to redline editorial corrections.  I did get a kick out of ISO-NE's correction to add offshore wind to DOE's narrow resource focus:
Page 49:
The best onshore renewable wind resources (i.e., those with the highest potential
capacity factors) tend to be located far from load and sometimes in areas with less
transmission than desired for effective resource development. The best offshore renewable wind resources, however, are often located close to load centers, as is the case with New England.
Bravo, ISO-NE!

Edison Electric Institute (EEI), the investor-owned utility lobbyist organization, told DOE to forget all about that NIETC stuff and to spend its time finding ways to streamline transmission permits on federal land.  Yes... that's just what's missing from America's National Parks -- more and bigger transmission lines!  Just think how sweet the Grand Canyon would look with a couple of huge transmission lines spanning it at its widest points!  And wouldn't Old Faithful be much, much cooler if it erupted into an overhead transmission line and created even more steam and maybe an electric arc or two?
  Yeehaw.... idiots!

WIRES, the transmission developer's lobbying group just seems to want to get its paws on a whole bunch of congestion data.  If DOE can't find or easily gather this data for WIRES's use in proposing competitive transmission projects, then WIRES thinks the DOE should pursue new legislation to obtain it, no matter how much providing this information burdens other utilities.


The American Wind Energy Association and Next Era Energy want DOE to allow transmission developers to do their own "congestion studies" and apply to DOE for designation of narrow "corridors" just wide enough for projects they want to build.  That's just ridiculous!!  A version of this bastardization of Sec. 1221 was proposed several years ago, and was promptly disposed of by Congress.  Not a good idea!  DOE doing this study and designating corridors is bad enough without throwing wide the door to self-serving "studies" and corridor requests inspired, not by need for new transmission, but by corporate greed.

And speaking of corporate greed, I've saved the best for last.  As expected, our heroes at Clean Line Energy just couldn't be left out of a process where it may benefit by using the government as its own personal land agent to take what it isn't granted by individual states.

Clean Line makes a bunch of obsequious comments that really don't do much but promote its own projects and display their self-centered stupidity. 

Clean Line made much of this diagram:
All of Clean Line’s projects originate in a Type 1 Conditional Constraint Area, identified by DOE in the 2009 National Electric Transmission Congestion Study (“2009 Congestion Study”) and illustrated in Figure 2. The 2009 Congestion Study defined a Type I Conditional Constraint Area as, “an area where large quantities of renewable resources could be developed economically using existing technology with known cost and performance characteristics – if transmission were available to serve them.” The 2009 Congestion Study also noted, “Construction of major new transmission projects would enable development of thousands of MW of new renewable generation” within these areas.
Hey, guess what, Clean Line?  The 2009 Congestion Study is no longer in effect and, in fact, was one of the straws that broke the DOE's back in Federal court.  Issuing a new report filled with old data is probably not a good plan.  And, hey, look at Figure 2 -- wind in those Type II Conditional Constraint Areas is conveniently located near all the big load centers that YOU are trying to reach with YOUR Type I projects.  Thanks for bringing up and illustrating just how worthless your projects really are!

Clean Line tells a HUGE lie:
Clean Line has engaged with thousands of local stakeholders in eleven states, where its five projects are actively under development.
Sort of sounds like Clean Line is having a great time making new friends, right?  In fact, Clean Line has inspired record opposition in every state it's entered, where "thousands of stakeholders" have spoken out against the project and participated in opposing Clean Line applications in the state permitting process.  Landowners routinely complain that they were not engaged by Clean Line, but found out about the project from neighbors and friends.  Clean Line's "public participation" process has been one gigantic failure.  Failure to properly consult with all stakeholders was a problem in DOE's last NIETC designation, and it's also the reason Clean Line is facing record opposition.  Ignoring landowner stakeholders does NOT nullify them, it only enrages and engages them!

Clean Line rumbles on about demand for its projects from unbuilt wind generators.  Note, Clean Line doesn't mention any interest from load serving entities, most likely because there isn't any!  And Clean Line's price for "all in" delivery includes the production tax credit that expired LAST year. 

Clean Line even elects itself to speak as a champion for you struggling farmers!

These are real projects, many of which have land leased for wind turbines from
farmers seeking new sources of income, as drought has made traditional farming livelihoods uncertain. Wind power represents new hope for drought-resistant income and economic development in regions of the country otherwise struggling with diminishing populations.
Looks like you all should give up farming and sit on the porch, watching the turbines turn and counting your cash.  Where's our food supposed to come from?  Make sure Clean Line gets at the end of any buffet line...

The next step is for DOE to "review and consider" comments on the draft study, and to prepare and release a final version of the study.  Watch this website, because it's likely to be another secret public process from our taxpayer-funded U.S. DOE!
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Townsfolk Invade Potomac Edison Rate Increase Public Hearings in Shepherdstown

10/7/2014

2 Comments

 
Around 100 townsfolk managed to find out about and invade the PSC's "public" hearings on Potomac Edison's proposed 17.2% rate increase in Shepherdstown yesterday.  Several dozen made public comment to Commissioner Jon McKinney, who was the only one to show up to listen.  Of course, that's really not remarkable, since there are currently only 2 commissioners and Commissioner Albert seems to fear for his own safety where townsfolk gather with their scary torches and pitchforks out here in the real world.

Despite announcing that the hearing wasn't a two-way conversation where he would directly interact with the commenters, Commissioner McKinney sure was argumentative with a handful of the people who gave testimony.  He took offense at comments that he believed were not factual, instead of simply listening.  I wonder why he thought it was his job to defend FirstEnergy like that?  The first thing Commissioner McKinney began to argue with a commenter about was the percentage of the proposed rate increase.  McKinney insisted that it was a 14% rate increase.  After much confusion and back and forth, PSC staff attorney John Auville managed to prevail on the fact that the rate increase for residential customers will be 17.2%.  This is the number Commissioner McKinney kept denying.  However, it is also the number listed on the rate increase pamphlet that FirstEnergy sent out in recent bills to customers.  I find it rather alarming that Commissioner McKinney refuses to admit the true magnitude of this rate increase on residential customers.  Commissioner McKinney's 14% increase figure included the average increase among different customer classes (residential, commercial and industrial).  Residential customers pay the highest rates, so their increase will be much higher.  Yesterday's public hearing attendees were all residential ratepayers.  Commercial and industrial customers hire lawyers and directly intervene in these kinds of cases.  Residential ratepayer participation is limited to public hearing commentary because the Commission believes residential ratepayers may only be formally represented by the state's Consumer Advocate and cannot protect their own interests in rate cases.  Therefore, the only number that mattered at yesterday's public comment hearing is:

17.2%

But this isn't the only "fact" Commissioner McKinney felt compelled to correct in his defense of FirstEnergy.... there were many other commenters who were informed that their public comments were incorrect as they made their way back to their seats.

Here's a nice summary of the comments made at the afternoon session.

And a TV news story.

It seems that The Journal is the only outlet that covered the evening session, where the Commission heard sharp criticism from Delegate Stephen Skinner.  Senator John Unger was understandably dismayed that neither the PSC nor the company bothered to notify him of the public hearing and he was unable to attend.  Senator Unger will follow-up with written comments.

Where were the rest of our legislators?  Better check those campaign finance reports for big FirstEnergy donations...

After listening to several dozen articulate and energetic commenters at both sessions, I've gotta say my favorite speaker was Robert Whalen, UWUA Local 102 President.   He spoke at length about FirstEnergy's many failures, from its skimping on maintenance to its refusal to hire enough workers.  He said that FirstEnergy only wants to spend on capital projects that earn a return, while attempting to avoid maintenance projects.  FirstEnergy is paid a fixed amount for maintenance work.  If the company doesn't spend all it collects, then that extra can be used to inflate earnings.  Whalen even voiced suspicions that work reported as maintenance is changed to capital by corporate management.  Is that sort of like cooking the books?  Whalen made many very constructive suggestions for ways that the Commission could work with the union to improve service.  As he succinctly put it... if you want to know the truth about FirstEnergy, you should ask the workers.

The Commission will hold formal evidentiary hearings on the rate increase later this month.  Your rates will go up next spring... it's only a matter of how much.

If you missed the public hearings, you can still file a written comment with the PSC here.
2 Comments

The DOE Wants to Know What You Think About its National Electric Transmission Congestion Study

9/13/2014

6 Comments

 
On August 19, the U.S. Department of Energy issued its long overdue "National Electric Transmission Congestion Study" for public comment.  You're the public!  Serendipity!

I'm not sure what DOE is trying to hide, but I didn't get any notice about this study, although I participated in one of the webinars, and usually get 15 copies of these kinds of notices forwarded to me from lots of different folks when they get them.  Nope.  *crickets*

Maybe it's because I've been engrossed in the project from hell and not paying attention to much else?
Virtual paper cuts be damned, I happened across it the other day while putting together some links for a transmission opposition group.  Serendipity, again!

It looks like the DOE really didn't pay much attention to the comments it received before writing this study.  They still seem to think that we need more transmission to make sure that every electron produced can be used anywhere else, no matter how far from the generation source.

The DOE is supposed to do a triennial congestion study.  That means every three years.  But after it got the stuffing kicked out of it in the 9th Circuit over its 2009 designation of National Interest Electric Transmission Corridors (NIETCs) without properly consulting the states, and without performing a proper environmental review of said corridors, we can understand why DOE is only just now getting around to the triennial study it was supposed to complete in 2012.  It's taken them this long to venture timidly out of their cave.  I'll guess that this "study" is only a tentative foray back into the game, since it states that another study will be completed in 2015, to keep to the original triennial schedule.  It's September, 2014 now, right?  DOE moves at a glacial pace...  Seriously?  What's the point of this year's study?

Anyhow... please do read the 175 page study, paying particular interest to your particular geographic area, or transmission project of concern.

And I'd like to mention a few special things that DOE said in this report that you should be thinking about while crafting your comments.

The first is a particular pet peeve of mine.  Perhaps in my next life I'll finally find time to do the full accounting of the TRUE cost of building new transmission that I've been constructing in my head over the last few years while listening to how transmission proposals affect hundreds of opponents across the country.  Maybe we can start making a dent in it by addressing it here.  DOE says:
Construction of major new transmission facilities, in particular, raises unique issues because transmission facilities have long lives – typically 40 years or more. Evaluating the merits of a proposed new facility is  challenging, because common practices take into account only those expected costs and benefits from a project that can be quantified with a high degree of perceived certainty. This has two effects:
First, it leads to a focus on the subset of cost and benefits that can be readily quantified. Not taking into account the costs and benefits that are hard to quantify has the effect of setting their value to zero in a comparison of costs and benefits.
Second, it leads to projections of costs and benefits that are generally on extrapolations drawn from recent experiences. Projections based only on recent experiences will not value the costs and benefits a transmission project will have under very different assumptions or scenarios regarding the future because they ignore or discount the likelihood of these possibilities. Such a narrow view of the range of costs and benefits that could occur provides a false sense of precision.
Transmission developers are all about tossing made up, speculative, or fantasy "benefits" onto the table in order to make their projects appear to pass a cost-benefit analysis.  But no one has ever quantified the REAL cost of transmission.  I'm not talking about a project's total capital spend, or its annual revenue requirement. I'm talking about the very real costs to landowners who are unlucky enough to be picked to sacrifice their homes, businesses, retirement, health, peace of mind and countless other intangible COSTS for the benefit of the electricity-slurping public in some far off city.  Market value payments for the involuntary sale of transmission right of way only attempt to compensate for the value of the land, not all the other costs to the landowner's way of life that can't be... in DOE-speak... "readily quantified."

Also, the DOE still seems to think that offshore wind is experimental. 
As will be discussed later in this chapter, many states adopted Renewable Portfolio Standards with requirements or goals to use more  renewable‐sourced electricity.
Because much of the best utility‐scale renewable resource potential is relatively remote from the load centers, the states then had to authorize new transmission construction to enable the desired renewable‐based electricity to reach the grid.
Maybe you can give DOE a link to its own map showing the best utility-scale renewable potential located just a few miles offshore, conveniently near load centers?  Quit tinkering, Einstein, and get 'er done!

And how about this? 
Many points of transmission congestion today result from the need to deliver electricity from
changing sources of generation. For example, generation sources are changing because of
state‐mandated RPSs. The best renewable resources (i.e., those with the highest potential capacity factors) tend to be located far from load and sometimes in areas with less transmission than desired for effective resource development. Existing transmission constraints may deter development of these resources. While this is not a challenge in all parts of the Eastern Interconnect, it is a principal cause of evolving congestion concerns in the Midwest.
Maybe you could let the DOE know about the economic benefits that come with LOCALLY-produced renewable energy?  Jobs, tax revenue and economic development happen where renewables develop.  States that buy, rather than create their own, renewables are only exporting their energy dollars to other states or regions and hurting their own communities.

Oh, and let's make this next part a fun scavenger hunt... can you find all the little hidden mentions of the Clean Line projects in this report?

So, what's the point here?  The DOE is going to use this draft and the comments it receives to create the final report.  From that report it may designate National Interest Electric Transmission Corridors (NIETCs).  NIETCs are very bad news, and a stupid idea left over from the 2005 energy policy act (don't ya wish your congress-person would get off their tookus and fix that mess?)
Designation of an area as a National Corridor is one of several preconditions required for
possible exercise by the Federal Energy Regulatory Commission (FERC) of “backstop” authority to approve the siting of transmission facilities in that area.
No.  No.  NOOOO!

So, what can you do?  Read the report.  Write a comment.  Send it here.  Do it now!  Comments are only going to be accepted until October 20.  If you don't participate, no one's going to care what you think later...
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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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