“Awarding a downward-biased ROE by hewing only to a ‘knee-jerk’ application of recent precedent would result in a regulatory ‘gotcha’.”
Now where have I heard that bumptious phrase lately? Could it be in PATH's "case-in-chief?"
"Now that investors are captive, awarding a downward-biased ROE would result in a regulatory “gotcha” that would violate regulatory standards and undermine the Commission’s own incentive policies."
Yup, same "expert." How many times will AEP pay this guy to theatrically yell "wolf?" As many as necessary, since they're using ratepayer funds to pay this "expert" to say the same thing over and over on different cases.
Quick, someone grab a violin, FERC is single-handedly destroying our economy! *shudders in horror*
I wonder if the Commission's eyes also roll back in their heads every time they read "regulatory 'gotcha"? Maybe they have a sort of office football pool going where they make bets on when Avera will pop up wailing "regulatory 'gotcha'" in a case. If not, they should consider it. Might be fun. At least more fun than reading Avera's billowing opinions over and over again.