Here's what PATH filed. (Note: 3.9MB file -- give it time to load. It's the best I could do to clean up the 10MB file PATH submitted, but that's another story.)
If you've read and understand the Formal Challenge that was filed on December 23, get ready to laugh. PATH counsel insults the Commission's intelligence by pretending: 1) the Commission didn't read the Challenge; 2) the Commission didn't understand the legal basis of the Challenge; and 3) the Commission didn't see or understand any of the evidence submitted as exhibits to the Challenge. PATH's attempt at performing a Vulcan mind meld on FERC's Commissioners fails miserably. This is PATH.
It's almost like PATH is embarrassed by their "Answer" and doesn't want anyone to see it. Why else would they have turned a 20 page word document and a two page spreadsheet exhibit into a 10MB pdf image file that chokes FERC's e-library and takes forever to download? PATH printed paper copies of the files and then ran them through a copy machine to result in a humongous, unweildy 10MB file that was uploaded to FERC. At least they didn't go so far as to "serve" it on the 80+ parties on the docket's service list and choke up everyone's email, but one could question whether "service" was actually effected ("I hereby certify that I have this day served the foregoing document by electronic service a copy of this filing...") by "serving" parties with a link to FERC's e-library that didn't work.
I'm not going to get into an analysis of just how bad PATH's "answer" is, but I will point out the funniest line in the whole document:
"In the wake of highly orchestrated and vocal opposition to the Project, PATH had a responsibility as the Project's developer to educate government officials, civic, community and business leaders, and the public at large, about the reliability benefits of improved transmission infrastructure in general, and the PATH Project in particular."
To fully appreciate the humor here, you've got to consider how PATH uses the term "highly orchestrated."
Orchestrate: arrange or direct the elements of (a situation) to produce a desired effect, esp. surreptitiously. Now isn't that the pot calling the kettle black?
And with that, we'll leave it in FERC's capable hands...