I've been following the story of PJM's new capacity import limit via RTO Insider
over the past couple months. Last Friday, PJM made its filing with FERC to change an agreement and tariff to impose the new limits before the next base residual auction.
It seems there is a B-I-G problem with low capacity prices. In addition to causing havoc with incumbent generator profits, PJM has come up with other reasons to "fix" its capacity market.
First though, let's look at how PJM's capacity market works. Capacity is a generator's ability to produce electricity. This is unrelated to energy actually produced in real time. Because PJM has to make sure there is enough electricity available to meet peak demand every year, it secures capacity, or the ability to produce electricity, three years in advance. Generators submit capacity bids in the auction. PJM stacks the bids by price. Beginning with the lowest price, bids are accepted until the capacity target is met. The highest price accepted is the uniform capacity price paid to all generators whose bid cleared.
Now let's move on to imported capacity. Generators outside PJM have been bidding higher and higher amounts of generation into PJM's auction, often at low prices. PJM's rules have allowed imported capacity into the auction even though it has no firm transmission path to be used by load in PJM. This sets up a scenario where PJM has cleared capacity that may never be delivered. The effect of this is that PJM may not have enough capacity to serve peak load. It also creates an effect where it can lower capacity prices for other generators in PJM because acceptance of low bids of imported capacity lowers the high bid that sets the capacity price for all generators.
So, on the one hand, it's a reliability problem, but it's also an earnings problem for PJM incumbent generators. PJM believes that artificially lowered capacity prices created by generation that may never serve PJM load is also causing retirement of existing generators in PJM, as well as preventing new internal generation from being built. PJM's market is supposed to encourage new generation to develop when capacity prices are high, adding more supply to meet demand. Instead, it was getting fake bids from outside the region, and that has skewed capacity prices.
Maybe generation from other regions can supply PJM cheaper than existing internal generation, but who wants to rely on generators thousands of miles away to supply their electricity? The longer electricity has to travel between generator and user, the more unreliable the supply becomes and the more electricity is simply wasted by losses along the way. It's encouraging that PJM finally acknowledges these simple physics of electric transmission, but the challenge now is to see if this new found realization is going to have any effect on the midwest wind transmission gold rush.
PJM's new rules make an exception for any external generator with firm transmission service that can be controlled by PJM and agrees to PJM's "must offer" requirement. This still allows external generators like the hated Clean Line Energy to be excepted from the limit. However, Clean Line only has 700 MW of firm transmission service for one of its lines with a capacity of 3500 MW. This still doesn't make Clean Line imports any more reliable than other imports though, nor does it provide this merchant transmission company with any of the east coast customers forced to buy renewables at any price that it seeks.
Let's keep an eye on this one and see who intervenes and complains at FERC (Docket No. ER14-503).
Mr. Glotfelty also noted that there could be circumstances under which the Grain Belt Project could find it necessary to depart from the cost recovery model described and instead seek cost recovery through regional or inter-regional cost allocation mechanisms.
Mr. Berry testified that while Petitioner currently has no plans to seek cost recovery for this Project through regional cost allocation, Petitioner is not in a position to make an irrevocable commitment not to seek cost allocation. He stated that such a commitment would be premature and would potentially go against the public interest. If regulations change in the future, an irrevocable commitment not to recover costs in a certain manner may compromise the ability of Petitioner to complete the Project.
Do you think maybe GBE isn't being completely honest with FERC? I do wonder how a situation that may compromise GBE is is against the public interest, if all project risk is being absorbed by GBE as a merchant transmission project?
GBE has presented an altered version of reality to FERC:
D. Public Outreach
Public outreach and active stakeholder involvement are key components of Applicant’s approach to development of the Project. Beginning in 2010, Grain Belt Express implemented an extensive, methodical, multi-level public outreach strategy across Kansas, Missouri, Illinois, and Indiana, which has resulted in more than 1,000 in-person meetings across the Project area as of November 2013. Grain Belt Express also has maintained an active presence online and through social media. The Project’s website, www.grainbeltexpresscleanline.com, has been actively updated since the beginning of the Project in 2010. Among other information, the website contains: a project video that describes the need for the Project and how Grain Belt Express will bring significant economic benefit to states through much-needed transmission expansion for new wind energy projects; an FAQ section for all stakeholders to learn greater details about the Project; a section on how local businesses can learn about opportunities to participate in the construction of the Project; and information regarding Project meetings, maps, studies, regulatory filings, and third-party resources. In addition, Grain Belt Express distributes a newsletter on a regular basis to hundreds of stakeholders. These newsletters provide information on Project milestones, recent events and meetings, as well as upcoming Project activities. The newsletter is available to anyone who is interested in receiving a copy. Applicant’s participation in multiple state regulatory proceedings also has publicized information regarding the Project.
E. Project Schedule
Applicant continues to work closely with land use and routing experts as well as landowners, local government officials, state and federal agencies, and other stakeholders in the areas where the Project will be built in order to gather input and determine the specific route for the transmission line in each state that it will traverse. Applicant is consulting experts on topics such as threatened and endangered species, archaeology, and cultural resources to ensure that appropriate considerations are taken into account in the routing decisions. Applicant expects to obtain all necessary authorizations from federal, state, and local governments and agencies for the Project by 2016.
I think I might know a few landowners who feel they have not been "closely worked with." In fact, the affected landowners in Kansas were the LAST ones to find out about GBE's project. Some of these landowners feel they were not properly notified under Kansas law, and even when they found out, they were denied effective participation in a matter that granted GBE the right to take their land by force. GBE even admits that, according to their public outreach plan, landowners are the last to be notified, after environmental groups, business groups, elected officials, local governments, and potential suppliers. It is only after Clean Line has drummed up support for its project by schmoozing and making dubious promises that it springs the project on affected landowners. In this way, Clean Line hopes that landowner concerns will be smothered by the group of MIMPSYs it has created.
However, FERC has no jurisdiction to right any wrongs made in the state regulatory process because it has no authority over siting and permitting. But, the dishonesty is galling.
GBE also tells FERC that it will shoulder all financial responsibility and risk for its project:
Applicant is assuming all market risk associated with the development and construction of the Project, and Applicant does not have and will not have any captive customers. Accordingly, Applicant has no ability to pass through the Project’s costs to captive ratepayers.
Well, not really. GBE is passing some of its risk and cost associated with its project on to affected landowners and local governments who are expected to shoulder uncompensated project costs. Such costs may include the expense of providing public safety services during construction and operation, use of roadways for construction and maintenance, reduction in tax base, lowered property values, interference with farming operations, health and safety risks of living and working in close proximity to the project, inverse condemnation takings, lowered farm operation income, and increased costs to farm around the project, and the list goes on.
GBE also mentions that there are other planned regional projects that will provide price competition. These other projects that are ordered by RTOs are financed by, and guaranteed cost recovery from, ratepayers. Ratepayers are assuming all risk of these other projects. If GBE causes the competing projects to fail, ratepayers will end up financing the failed projects, for which they will never receive any benefit.
In addition, GBE is promising FERC that it will abide by the Commission's rules about honest and aboveboard negotiation with potential customers. If landowners believe GBE has not been honest and aboveboard with them, how can FERC trust that GBE will keep promises made in this application? Many believe that GBE has not developed a good reputation of honestly attempting to follow regulation in the public interest. In fact, some believe that GBE's reputation is that of smart alec arrogance, always trying to manipulate regulation in order to advance its pecuniary goals.
For instance, after promising Kansas regulators 135 "operations" jobs in the state related to its project, GBE tells FERC the truth:
Once the Project is completed, Applicant will turn over operational control of the Project to an RTO, which will operate the line pursuant to a FERC-approved non-discriminatory rate schedule filed under the RTO’s OATT.
There is no RTO located in Kansas.
GBE also asks FERC for permission to use special selection criteria to evaluate offers. Preference will be given to potential customers who are willing to make "deposits" and shoulder some of the cost burden. In this way, GBE may be discriminating against customers who are not in a position to invest in its speculative project. I'm not sure this is what FERC really had in mind as non-discriminatory.
Keep an eye on this one. It's going to be interesting.
The trickle has turned into a steady drip. Pretty soon it's going to be a gusher.
What started with a successful complaint against New England transmission owners' ROE has been spreading like a virus of sanity.
A group of large industrial MISO consumers filed a complaint at FERC the other day asking to have the 12.38% base ROE lowered to 9.15% to reflect current market conditions, which would save MISO ratepayers $327M anually in unnecessary return paid to transmission owners.
But these complainants took their ROE complaint two steps further.
They also asked to have the debt/equity ratio capped at 50/50. For example, the equity return would be the above-mentioned 9.15%, but the debt return would be a much lower actual cost of debt percentage. These two percentages are combined to come up with the actual return. When the ratio is predominantly equity earning at a higher percentage, this creates a larger return for the transmission owner. By capping it at 50%, this would reduce transmission owner return and save consumers money.
However, the big thing you should be paying attention to is the request that the Commission eliminate previously granted ROE adders for RTO participation (50 basis points) and independent transco formation (100 points). The complainants argue that these adders have long since served their useful purpose and continuation only serves to unnecessarily drive up transmission owner profits.
It's about time this ridiculous transmission profits gravy train slows down. Viva sanity!
Pipelines are monopolies regulated by a little-known agency, the Federal Energy Regulatory Commission, which is financed not with tax dollars, but with fees paid by the regulated companies. In 2007 the commission authorized pipelines to collect the corporate income tax in the rates charged to customers. But instead of just charging the 35 percent federal tax on profits, the commission let companies charge what is known as the “grossed up” tax of 54 percent.
But since 1987 pipelines have been exempt from paying the corporate income tax as long as they are organized not as corporations, but as Master Limited Partnerships.
Forcing customers to pay a tax that never gets to government sounds like an issue someone might want to get before a judge. This issue was taken before three federal judges on the District Court of Appeals in Washington. Judge David B. Sentelle, a conservative, wrote that while he was troubled that taxes were even considered in setting pipeline rates, the court had no authority to interfere.
Remember, these regulators exist for your protection, little ratepayers.
This has been a long time in coming, but FirstEnergy was ordered on Friday to "submit a detailed plan for implementing audit staff’s recommendations and correcting journal entries reflecting an approximate $1.2 million refund to affected customers from its transmission-only subsidiaries with formula rate recovery mechanisms, including Trans-Allegheny Interstate Line Company, Potomac-Appalachian Transmission Highline, LLC, and American Transmission System, Incorporated."The first time this problem reared its ugly head was during the July 2011 PATH Open Meeting to review its 2010 actual transmission revenue requirement. At this phone "meeting" I notified PATH that I had found expenses of the Allegheny Energy/FirstEnergy merger in its PATH rates.In September, FirstEnergy subsidiaries PATH and TrAILCo made entries to their quarterly FERC financial filings to effect a credit for amounts wrongly charged to ratepayers in violation of the company's "hold harmless" guarantee to the Commission that it would not charge merger expenses to ratepayers except under certain circumstances. Over a million dollars was credited, but because PATH and TrAILCo made the correction in the normal course of business, it did not credit ratepayers for interest on the amounts wrongly recovered.Throughout the fall of 2011, PATH counsel continued to argue with me in discovery about recovery of merger expenses, refusing to own up to the fact that other merger expenses had been recovered. In October, PATH filed a motion to dismiss the first formal challenge, claiming that the involvement of Ali Haverty and myself in its annual update review was costly to ratepayers. In response, I pointed FERC to the more than $1M savings ratepayers had realized due to my identification of merger costs wrongly included in PATH's revenue requirement that were subsequently reclassed on the company's Form No. 1 filings.Shortly thereafter, FERC notified FirstEnergy that it was commencing an audit to determine if the company had complied with the Commission's order in the merger case. In December, TrAILCo filed a revision to its revenue requirements to correct merger costs "inadvertently" recovered. It claimed this error had been noticed during an "internal staff review." Right....If you take time to read FERC's FirstEnergy merger order, you will see that parties to that case had argued that adequate safeguards did not exist at FERC to prevent FirstEnergy from ignoring the hold harmless stipulation and recovering merger costs. FERC poo-poo'd this idea, insisting that their processes would be adequate to catch any wrongful recovery.And then FirstEnergy went ahead and recovered the merger costs anyhow! Did FERC's processes identify this wrongful recovery? No, I did. How embarrassing!FirstEnergy made a whole bunch of promises it never intended to keep in order to get its merger with Allegheny Energy approved. In addition to wrongly recovering merger costs in FERC jurisdictional rates, the company has saddled its West Virginia ratepayers with "acquisition adjustment" premiums flowing from its merger, as well as causing hardship to a whole bunch of distribution customers by cutting its meter reading services that resulted in huge erroneous bills and service shut offs.FirstEnergy's past bad deeds seem to be catching up with them lately, and the group of people and entities enjoying the show keeps growing.
Time is quickly running out to send in your RSVP for PATH's upcoming "Open Meeting." Follow the instructions here
to send your RSVP for the meeting to PATH's lawyer on or before Oct. 28.This isn't a real "meeting." An overconfident and arrogant PATH wasted your money for several years holding actual in-person meetings, complete with coffee & donuts,
at its fancy DC counsel's office. However, the whimpering remains of PATH now holds this "meeting" over the phone via conference call.During the call, you can ask PATH any questions about its plan to collect another $39.8M from you in 2014.
If you are a party to the abandonment case, you cannot ask about that case, but only about the information contained in the 2014 Projected Transmission Revenue Requirement filing linked above. Silly, yes, but when has PATH ever been logical?A lot of you have been asking me what's going on with the abandonment case and why PATH continues to collect money from you. Until that case settles or is heard, PATH is permitted to continue to collect the reimbursement it requested when it filed for abandonment. If, after the case is over, it is determined that PATH has collected more than it is allowed, PATH will have to refund the difference to you.So, send in your RSVP for the November 1 @10:00 a.m. phone meeting and belly up to the farcical ratepayer question bar.
If you don't come, PATH will think you don't love them anymore.
FirstEnergy's union workers have sent a letter to Federal Energy Regulatory Commissioners
asking that the agency's Office of Enforcement initiate an investigation into FirstEnergy's gaming of coal plant closures.The union states that "...the retirements may also have a detrimental effect on energy, capacity and ancillary prices in the PJM Regional Transmission Organization (PJM)."The union further reasons: "We are concerned that prematurely retiring such a large amount of apparently economic generating
capacity could lead to an increase in energy, capacity and ancillary service prices, to the benefit of FE's remaining facilities.""This concern is heightened by FE's failure to explain adequately the bases for its plans. With nearly two years remaining before the MATS closure deadline, FE's decision not to invest in MATS compliance fails to justify its evident rush to deactivate the plants. The decision is
likewise not explainable as the consequence of "continued low market price(s] for electricity." While the 2013 PJM capacity auction resulted in relatively lower prices (and a decline in the amount of coal-fired generation clearing the auction), those results apply to the period 2016-2017, which is after the April 2015 MATS compliance deadline. FE has not shown that
either plant is losing money, nor are we aware of any efforts to sell the plants. In these circumstances, a premature closing of the units may constitute a form of physical withholding and an improper effort to affect market prices."
In addition to being concerned about its own members, the union says, "...consumers deserve assurance that FE's action will not harm reliability or artificially inflate energy and capacity prices in PJM."They wrap up:"We urge the Commission to investigate FE's actions. In particular, the Commission should investigate FE's internally-stated reasons for the proposed closure date and any related business studies and cost-benefit analyses. Such an investigation would be in the public interest, consistent with the Commission's anti-market manipulation and rate regulatory authority, and in
the interest of the communities affected by FE's action."Why, sure, I'd love to see those studies and analyses, too. How about it FE, want to share?Chances of FERC acting on this? Slim to none. FE's plant closure market manipulation must be perfectly legal because those minding the store continue to allow it to happen unfettered. Of course it's going to artificially inflate energy and capacity prices that consumers must pay and create profits for the flailing FirstEnegy financials. That's what
this game is all about!Even rats know when to abandon a sinking ship. These guys should start looking for other jobs. I'd like to see Tony the Trickster keep just one plant running with the help of his million dollar henchmen and a couple of cute cocktail waitresses. Got candles?
Transmission's biggest cheerleaders met last month in San Diego
to talk about a subject near and dear to their wallets. During his presentation to his fellow speculators, Ray Wood, head of U.S. power and renewables at Bank of America Merrill Lynch said:
“Transmission assets, when they're already built, are goldmines,” he said. “They've got a long life, they're stable, and generally not as subject to tariff reductions as other asset classes because the percentage of the bill that ultimately goes to the end user that revolves around transmission is relatively light.”
Wood wasn't just bragging, however, but trying to convince everyone that transmission needs big, double-digit rates of return in order to attract capital.
According to Wood, funds for transmission are readily available, however transmission is so risky that no one wants to invest in it until a project has been awarded a "notice to proceed."
This is a lie. There is no risk involved in building transmission. Transmission incentives awarded by FERC routinely place all risk on consumers. One incentive awarded by FERC to all who ask is guaranteed recovery of 100% of prudently-incurred project cost. Another is the ability to collect a return on investment during the construction period (CWIP in rate base). The investor cannot lose if he is guaranteed to receive his entire investment back, plus a generous return, even before the project is constructed.
What Wood is whining about is that brief period of time between the day some transmission owner rolls out of bed with the idea to build a transmission goldmine, and the day incentives and a formula rate are approved by FERC. This is the only time when investment isn't earning a great big return. After that, it's all $$$$$!
Wood pretends that there's some further risk during other necessary approvals, such as a state CPCN or an environmental review. The investor is still earning during this time -- where's the risk? The only "risk" is that a project may be abandoned if it cannot buy necessary approvals, therefore the "sky's the limit" amount of investment that it was possible to make actually constructing the project is curtailed, and the investor is left with a smaller investment that is still earning around 12%. Oh, boo hoo.
And what about projects sponsored by transco spinoffs of gigantic investor owned utilities? These companies often self-finance the early cost of a project by borrowing at the parent company level at extremely low rates, and then earning a 14.3% return on that investment. In the case of the PATH project, the company never borrowed any money, however they still collected a 14.3 or 12.4 percent return on money they probably borrowed at 3 or 4%.
So, how do we fix this to make both Wood and electric consumers happy? How about setting limits on incentive rate of return periods to coincide with the "risky" periods of a transmission project? Transmission is only competing with other investments at the beginning. Once the investment is made and the project constructed, all risk disappears. So, what if incentive ROEs were gradually lowered over the life of the asset? As well, incentive ROEs should not kick in until an actual investment in the project has been made by an entity other than the company or its parent. Transmission owners are scamming us big time!
WIRES, the voice of the electric transmission industry
, has been as busy as a nasty, venomous, little bee trying to preserve its members’ ability to harvest buckets of ratepayer cash building new transmission of dubious necessity.
On another prong of its diabolical pitchfork, WIRES takes on the problem of recent FERC return on equity complaints alleging that transmission ROEs based on market conditions prior to the big crash are set too high. One such complaint was ruled on yesterday
, when a FERC administrative law judge found that the 11.14% base ROE for New England transmission owners was unjust and unreasonable and recommended that it be reduced to 9.7%. The ALJ found that FERC’s ROE “zone of reasonableness” determined by the prior DCF analyses was inappropriate because there has been so much economic change.
With that in mind, we can approach WIRES’ petition to FERC
requesting that it revamp or replace its current DCF process for setting returns, deny any future rate of return complaints under sec. 206 of the FPA as long as the ROE still falls safely within the zone of reasonableness, and that the “benefits” of a transmission project be considered as a factor worthy of a higher ROE than would ordinarily be found to be just and reasonable. “Petitioner asks the Commission to explore methodological options that will reduce or eliminate the uncertainties and risks to investors and to customers and avoid potential reductions in investment in needed transmission facilities, higher costs, project delays, and disruption to infrastructure planning and growth.”
WIRES intends to provide electricity consumers with greater stability and predictability regarding regulated rates of return on equity (or “ROE”) for existing and future investments in high voltage electric transmission infrastructure. Well, gee, thanks, WIRES, I know that dilemma keeps everyone up at night… NOT. Are you sure you’ve really got the welfare of electricity consumers in mind? Who designated you as our representative anyhow? WIRES does NOT speak for electric consumers.
WIRES is simply stamping its gold-plated feet because the usurious ROEs it had gotten used to have come to an end. Now they want FERC to shore things up for them, and do it in a big hurry and in a way that shuts the consumers who will end up paying for it all out of the process. WIRES is frightened by all the recent section 206 complaints that are eating into transmission profit margins, and that’s because the complaints are well-founded.
Rah! Rah! Rah! Who loves transmission? Gimme a W, gimme an I, gimme an R, gimme an E, gimme an S… what does that spell? An expensive, unneeded transmission line in everyone’s back yard! Hooooooo-rayyyyyyyy!
WIRES says it’s all FERC’s fault for making the transmission biz just so gosh darn lucrative: “…a major and substantial impetus for new investment was supplied by federal regulatory initiatives promoting regionally competitive power markets and transmission open access. It is no accident that modernization and expansion of the nation’s transmission system has coincided with implementation of the Energy Policy Act of 2005 and its directive to the Commission to provide “incentive-based rate treatments” for jurisdictional public utility transmission projects, including “a return on equity that attracts new investment in transmission facilities (including related transmission technologies).”
And therefore, it is FERC’s responsibility to continue to champion more transmission because transmission owners now depend on it as a profit center: “Despite the continuing challenges to its planning and siting, transmission is the “critical link” between generation and customers, and its vitality is key to FERC’s bulk power market policy objectives. The industry’s principal game-changing developments of the last two decades -- open access and comparability requirements, regional wholesale power markets, accelerating network integration, the arrival of non-utility transmission investors as well as utility diversification into commercial transmission, deployment of digital monitoring and control technologies, and new forms of renewable energy -- depend significantly on the adequacy and efficiency of the grid. In recognition of that fact, transmission has emerged as a separate business and profit center, even for many incumbent transmission providers whose transmission investments were historically the by-product of service to native load.”
Well, someone has worked quite punctiliously on a strategy to dig in a foothold for transmission at a time when the composition of future energy generation and delivery is enormously uncertain, haven’t they? I don’t think this is a wise strategy for consumers, who may end up holding a gigantic bill for infrastructure that is not useful or economic. Instead of rushing headlong into $300B of new transmission intended to support more centralized generation and foster larger and costlier deregulated electricity markets, we should first be tackling the question of necessity. Even WIRES agrees with this point. “Micro-grids, distributed generation, and energy storage technologies represent new and potentially important competition for investors’ resources.”
WIRES’ petition makes all sorts of spurious claims that all begin with a version of “once upon a time”: “WIRES believes there is a binding norm obtained through rulemaking that would do more to ensure consistency than a policy statement. However, the need to address this particular matter within a short period of time and the familiarity of Commission staff and industry parties with the issues argue for a short comment period, followed by a Statement of Policy. Such action would shed light on the Commission’s intentions going forward while preserving its flexibility in the face of changing facts and events.”
Translation: "Let’s hurry up and get this done before someone notices!" “Petitioner believes the investment community is, or will soon become, apprehensive about the prospect of declining transmission-related ROEs and other regulatory uncertainties.”
Translation: “Wah! You’re impeding our profits!” “Petitioner believes that, even the most substantial increases in regulated transmission investment would rarely, if ever, result in transmission being more than one-fifth of retail rates regionally. Of course, the rate impact of regulated transmission investment on individual customers is reduced, perhaps dramatically, in relation to how broadly costs are shared. Moreover, adequate transmission enables more efficient use of generation resources; those savings will tend to offset, at least in part, any increases in transmission rates.”
Translation: “Those pesky consumers won’t notice the disgustingly high profits we’re making if we can socialize the costs broadly enough.” Again… who appointed WIRES to speak for consumers? “Petitioner believes that the subjective judgments and evolving standards associated with application of DCF in litigated cases will significantly affect investor behavior and, if left to evolve solely through litigation, will add greater regulatory risk and uncertainty to the recognizable barriers that transmission development already faces.”
Translation: “If FERC doesn’t put a stop to ROE complaints, the investors are going to find other investments that pay higher returns, well, if they can find any that pay more than 12 – 14%, which they can’t.” “In WIRES’ view, one key to sustaining transmission investment is rational application of the DCF methodology or such other methodologies as may appropriately fit the financial environment and Commission objectives.”
Translation: “And only high ROEs are rational, so therefore, show us the money!” “Petitioner contends that challenges to existing or proposed rates of return need not be resolved simply on the basis of a mechanical application of the DCF model. Regulation should maintain a reasonable relationship between a project’s (or group of projects’) long-term benefits, including those that planners and regulators expect and those that flow from evolving grid operations, and the costs customers pay for securing those benefits through new transmission facilities or upgrades. Transmission benefits should therefore be part of any consideration of whether customers have been, or are likely to be, harmed by an existing allowed return.”
Translation: “We’ll make up new “benefits” for consumers if you just let us keep robbing them!” “We are not suggesting a performance-based regulatory regime, as that is necessarily beyond the scope of the brief generic reassessment that this Petition recommends.”
Translation: “But let’s not be hasty here! Even though Congress expressly ordered that transmission incentives be subject to performance standards, FERC has failed to hold us to any standards, and that’s the way we like it!”
FERC simply cannot continue to reward failure and poor planning with unjust and unreasonable rates. If you’d like to read responses to this ridiculous and dangerous petition and/or follow this docket, you may find it here
by searching for Docket No. RM13-18.
All this smoke and thunder signifies the wrath of a dying industry. Change or die
, fellas, the future is here!