The Federal Energy Regulatory Commission's two-step march toward expanding the financial incentives it awards to transmission owners seems to have lost its rhythm today as a deluge of thoughtful comments criticizing FERC's approach floods in.
A group of grassroots consumer organizations have filed joint comments on the Rulemaking proceeding. You can read their comments here. As consumers who pay the incentives granted by the Commission, these groups have a unique interest in the outcome of this regulatory extravaganza. FERC says it is making these changes to "benefit" consumers. However, the changes all seem to increase the costs consumers pay, without actual benefits.
Well, ya know what C.S. Lewis said about that... “Of all tyrannies, a tyranny sincerely exercised for the good of its victims may be the most oppressive.”
FERC still hasn't realized the mistake it made when initially creating incentives. It's something we've been on them about since the first "review" of the incentives back in 2011. The language in the statute FERC is trying to carry out requires:
A group of grassroots consumer organizations have filed joint comments on the Rulemaking proceeding. You can read their comments here. As consumers who pay the incentives granted by the Commission, these groups have a unique interest in the outcome of this regulatory extravaganza. FERC says it is making these changes to "benefit" consumers. However, the changes all seem to increase the costs consumers pay, without actual benefits.
Well, ya know what C.S. Lewis said about that... “Of all tyrannies, a tyranny sincerely exercised for the good of its victims may be the most oppressive.”
FERC still hasn't realized the mistake it made when initially creating incentives. It's something we've been on them about since the first "review" of the incentives back in 2011. The language in the statute FERC is trying to carry out requires:
16 U.S.C. 824s(a)“Not later than 1 year after August 8, 2005, the Commission shall establish, by rule, incentive-based (including performance-based) rate treatments for the transmission of electric energy in interstate commerce by public utilities for the purpose of benefitting consumers by ensuring reliability and reducing the cost of delivered power by reducing transmission congestion.”
FERC changed that "and" to "or" and has been wrongly awarding incentives to projects that didn't do both ever since.
Finally, hooray, this mistake seems to be gaining wider notice and has been mentioned by numerous other commenters who take issue with FERC's either/or purpose for incentives.
Interest in this Rulemaking is off the charts. The vast majority of the comments I've read so far embody this quote from California Wildnerness v. DOE: “An agency is not required to adopt a rule that conforms in any way to the comments presented to it. So long as it explains its reasons, it may adopt a rule that all commentators think is stupid or unnecessary.”
I'm still trying to find a comment that doesn't think this new rule is stupid or unnecessary.
AND
AND
AND
And this is probably going to end up in court, unless Congress steps in to repeal this stupid and unnecessary law.
Finally, hooray, this mistake seems to be gaining wider notice and has been mentioned by numerous other commenters who take issue with FERC's either/or purpose for incentives.
Interest in this Rulemaking is off the charts. The vast majority of the comments I've read so far embody this quote from California Wildnerness v. DOE: “An agency is not required to adopt a rule that conforms in any way to the comments presented to it. So long as it explains its reasons, it may adopt a rule that all commentators think is stupid or unnecessary.”
I'm still trying to find a comment that doesn't think this new rule is stupid or unnecessary.
AND
AND
AND
And this is probably going to end up in court, unless Congress steps in to repeal this stupid and unnecessary law.
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