Spiegel & McDiarmid submitted a letter today on behalf of numerous organizations and states summarizing the general gist of the comments, in case FERC is having trouble sorting them out.
It makes perfect sense. But it doesn't make a bunch of unearned profit for transmission owners. Cue the whining... the IOUs should be responding in... 3, 2, 1...
It could have been better if they hadn't started out spelling two out of four Commissioners' names wrong. And, that word "incentive" is such a toughie! It isn't a verb. Even grammar experts can't agree on how to turn it into an action word. However, once you've picked one of the bastardized verb versions, please stick with it throughout the document. I'm glad this isn't an English 101 test.
But, hey, something amazing happened with this letter... WV's Consumer Advocate finally weighed in on the matter of FERC's transmission incentives! If he'd gotten involved sooner maybe they would have found out that there's already plenty of transparency between costs and reward in a formula rate. It's that line item called "Return." It's not that hard, Byron.