Big news! Today the staff of the West Virginia Public Service Commission filed a Motion to Dismiss the Filing as Insufficient or in the Alternative, Require PATH to Request a Tolling and Implement Further Case Processing Procedures.
In the motion, the staff asserts that certain developments pertaining to the status of the Mt. Storm-Doubs 500kV line, as well as other developments, make the current application incomplete. As a result, the Commission does not have all the information it needs to properly evaluate this project and reasonable alternatives. Therefore the Staff moves the Commission to either dismiss this case or require PATH to request a tolling sufficient to allow the Commission to implement further case processing procedures to assure a complete review of the application by the parties and the Commission.
Essentially, the staff has also noticed the robust odor of "barnyard" coming off PJM's continued insistence that PATH is the "most robust solution to the reliability
needs we identified", which flies in the face of PJM's approval of Dominion Virginia Power's filing for rebuild of the Mt. Storm-Doubs line. While PJM approved this rebuild, they are completely ignoring the increase in capacity the rebuild will provide in their modeling for the need for the PATH project. In addition, the staff believes that Dominion's alternatives to the PATH project that were filed earlier this year have not been given adequate consideration, and in fact the staff seems to be leaning toward Dominion's Alternative 1 as the only "solution" needed for at least the next 10 years. This solution will be much cheaper, will cause much less disturbance to the environment, and requires no acquisition of new rights-of-way (condemnation of property). Dominion's Alternative 1 will save the ratepayers millions, if not billions, of dollars in the long run. The cost of PATH's acquisition of land and land rights for their project are added to the ratebase, upon which ratepayers pay a return (in 2011 average of 50% equity at 14.3% and 50% debt at 6.64%). Items in the ratebase are subject to depreciation, except for land, which never depreciates, therefore subjecting the ratepayers to paying that return on land acquisition for eternity. Dominion's proposal will save us a bundle in long-term costs!
The staff also mentions the MAPP line, which was recently resurrected in Maryland. The combination of the MAPP line and the Mt. Storm-Doubs rebuild leaves no reactive criteria violations, according to the staff's motion.
The motion also questions PJM's treatment of other proposed alternatives to the PATH project.
And here's my favorite part of the motion:
"It is ludicrous to continue to move forward with the PATH project while major changes are being contemplated for critical transmission infrastructure that should be factored into assessment of the need for PATH."
I think that about says it all!
Please remember that this is only a motion -- the WV PSC Commissioners will be the ones who make the ultimate decision on the disposition of PATH's application in this state. The staff has asked for:
"Staff moves the Commission (1) to dismiss PATH’s Application without prejudice; ( 2 ) permit for re-filing once a new analysis has been completed that includes all the recent developments;(3)order the Applicants to file updated testimony in regards to the economic and environmental aspects of this project, including a discussion of the need to rebuild the Pruntytown-Mt. Storm line. Alternatively, Staff does not object to proceeding with PATH’s pending Application if PATH submits a written document requesting to toll the statutory time line until such time as these additional filings can be made. Parties, including Staff and the CAD, will soon expend significant resources on expert fees and filing direct testimony. Accordingly, Staff asks the Commission to rule on this motion as expeditiously as possible."
Now the real fun begins as we watch to see how the other two state commissions react. Will they join in kicking PATH while they're down? I hope so! No mercy!
Journal article (and no, I didn't really say that -- substitute the word "hoping" for the word "before" and that's a lot closer to what I said)
Frederick News Post (this article was part of a half-page spread that also featured a story about the PATH Formula Rate Preliminary Challenge -- see The Collection for link to that story)
In the motion, the staff asserts that certain developments pertaining to the status of the Mt. Storm-Doubs 500kV line, as well as other developments, make the current application incomplete. As a result, the Commission does not have all the information it needs to properly evaluate this project and reasonable alternatives. Therefore the Staff moves the Commission to either dismiss this case or require PATH to request a tolling sufficient to allow the Commission to implement further case processing procedures to assure a complete review of the application by the parties and the Commission.
Essentially, the staff has also noticed the robust odor of "barnyard" coming off PJM's continued insistence that PATH is the "most robust solution to the reliability
needs we identified", which flies in the face of PJM's approval of Dominion Virginia Power's filing for rebuild of the Mt. Storm-Doubs line. While PJM approved this rebuild, they are completely ignoring the increase in capacity the rebuild will provide in their modeling for the need for the PATH project. In addition, the staff believes that Dominion's alternatives to the PATH project that were filed earlier this year have not been given adequate consideration, and in fact the staff seems to be leaning toward Dominion's Alternative 1 as the only "solution" needed for at least the next 10 years. This solution will be much cheaper, will cause much less disturbance to the environment, and requires no acquisition of new rights-of-way (condemnation of property). Dominion's Alternative 1 will save the ratepayers millions, if not billions, of dollars in the long run. The cost of PATH's acquisition of land and land rights for their project are added to the ratebase, upon which ratepayers pay a return (in 2011 average of 50% equity at 14.3% and 50% debt at 6.64%). Items in the ratebase are subject to depreciation, except for land, which never depreciates, therefore subjecting the ratepayers to paying that return on land acquisition for eternity. Dominion's proposal will save us a bundle in long-term costs!
The staff also mentions the MAPP line, which was recently resurrected in Maryland. The combination of the MAPP line and the Mt. Storm-Doubs rebuild leaves no reactive criteria violations, according to the staff's motion.
The motion also questions PJM's treatment of other proposed alternatives to the PATH project.
And here's my favorite part of the motion:
"It is ludicrous to continue to move forward with the PATH project while major changes are being contemplated for critical transmission infrastructure that should be factored into assessment of the need for PATH."
I think that about says it all!
Please remember that this is only a motion -- the WV PSC Commissioners will be the ones who make the ultimate decision on the disposition of PATH's application in this state. The staff has asked for:
"Staff moves the Commission (1) to dismiss PATH’s Application without prejudice; ( 2 ) permit for re-filing once a new analysis has been completed that includes all the recent developments;(3)order the Applicants to file updated testimony in regards to the economic and environmental aspects of this project, including a discussion of the need to rebuild the Pruntytown-Mt. Storm line. Alternatively, Staff does not object to proceeding with PATH’s pending Application if PATH submits a written document requesting to toll the statutory time line until such time as these additional filings can be made. Parties, including Staff and the CAD, will soon expend significant resources on expert fees and filing direct testimony. Accordingly, Staff asks the Commission to rule on this motion as expeditiously as possible."
Now the real fun begins as we watch to see how the other two state commissions react. Will they join in kicking PATH while they're down? I hope so! No mercy!
Journal article (and no, I didn't really say that -- substitute the word "hoping" for the word "before" and that's a lot closer to what I said)
Frederick News Post (this article was part of a half-page spread that also featured a story about the PATH Formula Rate Preliminary Challenge -- see The Collection for link to that story)
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