In the NOI, Promoting Transmission Investment Through Pricing Reform, FERC is seeking comments about the effect of its incentives on promoting transmission. If you're going to comment, you need to understand what the incentives are, and what they are intended to do.
Let's back up a bit here and take a look at the beginning of the NOI. Beginning on page 10, A. Section 219 (a) Statutory Threshold, explains the first step that makes a transmission project eligible for incentives. FERC has established rebuttable presumptions in order to make this determination.
A project is eligible for the incentives if one of two requirements has been met:
If either of these requirements has not been met, the applicant has the option of making an independent showing to FERC that the project either satisfies a need for reliability or reduces transmission congestion in order to lower costs to consumers.
If a project cannot jump this initial hurdle, they are not eligible for transmission incentives and it's all over.
But, what happens when a project initially meets the rebuttable presumption, however the basis for their rebuttable presumption subsequently evaporates?
That's exactly what has happened with the PATH project. PATH was removed from the RTEP. It has not been approved by any state commission. PATH has not made an independent showing to FERC that their project ensures reliability or reduces congestion (they couldn't anyhow -- PJM's removal from the RTEP prevents this argument). However, PATH (and FERC by sitting around doing nothing about it) are ignoring this fact. PATH continues to collect all the benefits of incentives for which they no longer qualify. Why is this being allowed to happen? It's costing the consumers money!
FERC asks several questions about this requirement beginning on page 11. Q14 sort of addresses this issue -- it's the closest FERC gets, so it will suffice as a starting point for your suggestions and ideas regarding how to prevent another PATH from happening and robbing the consumers blind.
If you found this helpful in crafting your comments, you are encouraged to browse the entire FERC Transmission NOI category at StopPATHwv.com for other useful material. You don't have to comment on all aspects of the NOI if that's too burdensome. In fact, if you want to concentrate in detail on just one aspect that interests you and about which you have strong feelings, that's a perfectly acceptable approach to producing effective comments.
Lots more stuff to come... keep checking back.
Let's back up a bit here and take a look at the beginning of the NOI. Beginning on page 10, A. Section 219 (a) Statutory Threshold, explains the first step that makes a transmission project eligible for incentives. FERC has established rebuttable presumptions in order to make this determination.
A project is eligible for the incentives if one of two requirements has been met:
- The project has been approved by a RTO through their planning process.
- The project has been approved by necessary state public service commission(s).
If either of these requirements has not been met, the applicant has the option of making an independent showing to FERC that the project either satisfies a need for reliability or reduces transmission congestion in order to lower costs to consumers.
If a project cannot jump this initial hurdle, they are not eligible for transmission incentives and it's all over.
But, what happens when a project initially meets the rebuttable presumption, however the basis for their rebuttable presumption subsequently evaporates?
That's exactly what has happened with the PATH project. PATH was removed from the RTEP. It has not been approved by any state commission. PATH has not made an independent showing to FERC that their project ensures reliability or reduces congestion (they couldn't anyhow -- PJM's removal from the RTEP prevents this argument). However, PATH (and FERC by sitting around doing nothing about it) are ignoring this fact. PATH continues to collect all the benefits of incentives for which they no longer qualify. Why is this being allowed to happen? It's costing the consumers money!
FERC asks several questions about this requirement beginning on page 11. Q14 sort of addresses this issue -- it's the closest FERC gets, so it will suffice as a starting point for your suggestions and ideas regarding how to prevent another PATH from happening and robbing the consumers blind.
If you found this helpful in crafting your comments, you are encouraged to browse the entire FERC Transmission NOI category at StopPATHwv.com for other useful material. You don't have to comment on all aspects of the NOI if that's too burdensome. In fact, if you want to concentrate in detail on just one aspect that interests you and about which you have strong feelings, that's a perfectly acceptable approach to producing effective comments.
Lots more stuff to come... keep checking back.
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