One of the advantages West Virginia has historically enjoyed when attracting and supporting businesses in the state has been low electric rates.  However, that advantage has been severely challenged over the past four years with rates soaring nearly 50 percent.  If we allow "business as usual" to continue and make no attempt to develop a logical plan to keep electric rates reasonably in check, that advantage will be lost forever.

When electric rates rise, businesses must find a way to cover the increased cost.  That could mean cutting back on staff, resulting in increased job loss throughout the state.  It could also mean that businesses will simply throw in the towel and close altogether.  Or, perhaps they will simply relocate to another state where sensible planning provides electric rate certainty that businesses can rely on.  The ultimate outcome of West Virginia's lack of planning to control skyrocketing electric rates will most likely be a combination of all the above.

The Power Line blog reports today that a "whispering campaign" has been started at the legislature by power company lobbyists who contend that SB162, requiring electric companies to submit least-cost plans to the Public Service Commission, will cause job loss in the state.

The power company's scare tactics are completely untrue, as The Power Line aptly points out.  In fact, the opposite is true.  Failure to institute least-cost planning will lead to wide-spread job loss across all industry and business sectors in the state.

Power company lobbyists say least-cost planning "would result in coal miners losing jobs and the power companies’ coal fired plants closing down."  The coal industry may be in trouble, but it has nothing to do with least-cost planning in West Virginia.  The price of coal has gone up due to an increase in exports to other countries who will pay dearly for it.  In contrast, there has been a corresponding decrease in gas prices due to excess production.  The gas vs. coal electricity generation war has begun.  West Virginia's electric consumers have absolutely no fault in this and cannot solve it by paying more for electricity.  It's an economic problem we can't afford to straighten out.  Electric consumers don't have a dog in this fight.

Adding to the dilemma is decreased electric demand related to energy efficiency and demand response occurring in east coast states.  West Virginia exports 80% of the electricity generated in the state to east coast markets.  When the east coast isn't buying it, and is in fact building new gas-fired generation to meet their own needs, it causes electric rate increases here in West Virginia because power company sales to the east coast are part of what has kept our rates low in the past.  This fact is also beyond the control of West Virginia electric consumers.

As well, there's an incredible amount of waste going on at West Virginia's electric utilities that has nothing to do with fuel costs.  For instance, did you know that AEP's former CEO was allowed free use of the corporate jet for personal travel as part of his employment contract?  There's certainly plenty of belt-tightening that can be done at the corporate level before placing their economic woes at the doorstep of West Virginia's electric consumers.

The power company lobbyists are lying to your elected representatives.  The legislators who continue to stall SB162 are choosing to throw their constituents under the bus, and are embarking on a very slippery slope which will endanger the prosperity of West Virginia business and industry.

Look no further than Ohio for a recent example of what can happen when huge electric rate increases, cooked up through a corrupted Public Utilities Commission process, hurt business. 

West Virginia can, and must, do better by instituting least-cost planning.

PJM is still refusing to give up on the PATH Project boondoggle.  With the 2011 RTEP just a week away, PJM continues to recommend that PATH and fellow Project Mountaineer boondoggle, MAPP, remain in the la-la land of "abeyance" until the May 2012 RPM auction.  Project Mountaineer boondoggle Susquehanna-Roseland is supposedly still "needed," according to these slides.

There is no longer any "reliability" or economic justification for these projects!  They simply hang around like a stale house guest and continue to cost electric consumers in thirteen states higher electric bills that they can ill afford.

The last RPM auction in May 2011 showed that prices between eastern and western PJM have nearly levelized:

"In PJM's MAAC area the price of capacity will be $136.50 MW-day, a decrease of about $100 from last year.  (The MAAC price applies to the transmission zones of Baltimore Gas and Electric Company, Metropolitan Edison Company, Pennsylvania Electric Company, and PPL Electric Utilities, Atlantic City Electric, Delmarva Power, Jersey Central Power and Light Company, PECO, Public Service Electric and Gas Company, and Rockland Electric Company.) The non-MAAC region, will pay the RTO price of $125.99, an increase of about $100. This region includes western Pennsylvania, western Maryland, Ohio, Indiana, Michigan, Kentucky and Virginia.

"The convergence of prices between the eastern and western regions of the market is primarily driven by the significant reduction in forecasted load growth through 2014/2015," Ott said."

Any justification for Project Mountaineer has long since evaporated.  "Congestion" has eased, coal-fired electricity has become more expensive, and gas-fired generation in the East Coast load pockets has become cheaper than coal-by-wire.  In addition, new gas-fired generation is being proposed near load.  Any supposed "reliability" or "congestion" crisis has eased.

As far as Susquehanna-Roseland, PJM really needs to take a fresh look at that project.  Their current plan is complete overkill.  The existing line may be near the end of its useful life, however a simple rebuild may be the answer, instead of a brand new double-circuited 500kV line.

It's always "one more auction" with these guys, and there is always another auction down the road for the project owners to pin their hopes on.  Project Mountaineer was an embarrassing blunder on the part of PJM.  Let's put it to rest, move on, and quit wasting the scarce resources of PJM electric consumers on useless boondoggles!

I think someone handed the Little Drummer Boy the wrong script a couple weeks ago when he sat down with a reporter from the State Journal.

LDB says, "APCO – this territory – has borne the brunt of pretty sizable (rate) increases, and it's mainly due to environmental retrofitting of coal units. Still, the rates are lower than they are in other parts of the country, but that doesn't matter to the people paying the bills. The fact is that we've gotten ahead at APCO, so it should moderate future increases."

He also says that 35% rate increases are "needless."

But last week, AEP's spokes-flack said the rate increases were caused by coal that has already been burned:

"We have already bought the coal, we have already made the power and customers have already used that power," Matheney said. "We're facing this large amount of money that has already been spent."

I'd like to introduce you to

You two should get together some time and get to know each other.

Or, maybe the rate increases are caused by excessive AEP executive salaries

Or maybe the rate increases are caused by zombies?

FERC's Commissioners rubber stamped PATH's ROE Settlement today.  No surprise there.  The 14.3% ROE they were originally awarded is history, replaced by 12.4% and bolstered by a refund to ratepayers of over $2M.  Watch for it in your next bill ;-)  (I'm being sarcastic here folks, you're not going to notice any difference).

The small bit of news came from the Commissioners' attempts to do a little housekeeping on PATH's open FERC dockets.

In their letter order, FERC wants to inform all of you citizen ratepayers who submitted comments about PATH's suspension last year that the comments are "beyond the scope of the proceeding, and therefore will not be addressed in this proceeding."  I think that means that you are dismissed, but read it for yourself.  The "you" referred to by FERC is our pal Randy Palmer.

"On March 7, 2011, you also filed in Docket No. ER08-386-000, for informational purposes only, an update on the status of the PATH Project (Project Update). You indicate that PJM Interconnection, L.L.C. directed PATH to suspend development of the PATH Project other than activities needed to maintain the  PATH Project in its current state. Several individuals filed comments in response to this informational filing on the
Project Update, and PATH filed answer to these comments. These comments raise various challenges regarding the location of the Project, the need for the Project, and its costs. These comments raise issues which are beyond the scope of this proceeding, and
therefore will not be addressed in this proceeding."

I guess the Commissioners missed those parts of certain comments where it was pointed out that PATH's rebuttable presumption, upon which the granting of incentives was based, has run away from home.

However, the two outstanding Formal Challenges live on:

"Consistent with the Commission’s delegated letter order issued in Potomac-Appalachian Highline Transmission, L.L.C., Docket No. ER09-1256-000 at 2-3 (February 2, 2010), PATH’s Annual Updates and any related  challenges filed in the above dockets and Docket No. ER09-1256-000 will be addressed in Docket No. ER09-
1256-000, consistent with the formula rate  implementation protocols providing specific procedures for notice, review, and challenges to these Annual  Updates."

FERC also wanted to let Randy know:

"The Commission retains the right to investigate the rates, terms, and conditions under the just and reasonable and not unduly discriminatory or preferential standard of section 206 of the Federal Power Act, 16 U.S.C. § 824e (2006)."

And I think that will about do it for now.

I don't have the time or energy left to cross post this... just go here and read it.

AEP subsidiary Appalachian Power sent a special Valentine to all their customers in West Virginia yesterday.  The Valentine admits that the company can no longer provide electric service to its customers at a rate that they can afford to pay.  This is the result of AEP's head-in-the-sand denial of the steadily increasing costs of the coal that fuels 99% of their electric generation that is sold to West Virginians.

Appalachian Power's lobbyist has been trying to short-circuit a WV Senate bill that would require power companies to file Integrated Resource Plans.  An IRP provides the Public Service Commission with the utility's plan for supplying electricity to its customers in the most cost-effective manner.  It requires the utility to evaluate costs and benefits of choices for power purchase contracts, the cost of new and existing generation facilities, making investments in demand-side resources, including energy efficiency, and to diversify its supply portfolio in order to protect ratepayers from unmanageable rate increases caused by over-dependence on only one source of fuel.

Yesterday, Appalachian Power's lobbyist introduced identical bills in both the House and Senate that would, "authorize the Public Service Commission of West Virginia to consider and authorize the recovery of certain expanded net energy costs by certain electric utilities through the issuance of consumer rate relief bonds where such financing is reasonably expected to result in cost savings and rate mitigation to customers when compared with traditional financing or cost-recovery methods."

Appalachian Power's spokeswoman explained it like this:

"We have already bought the coal, we have already made the power and customers have already used that power," Matheney said. "We're facing this large amount of money that has already been spent."

The utility estimates that its yearly per-ton coal costs jumped 70 percent between 2007 and this year. Matheney said the normal process has proved unable to cope with such circumstances.

"When it doesn't work well is when those expenses accumulate much faster and grow to become much larger than you anticipated," Matheney said. "We feel that's where we are right now."

What Appalachian Power intends to do with this legislation is to put their West Virginia customers into long-term debt to pay these fuel costs, while the company is immediately reimbursed for their out-of-pocket costs caused by their own bad planning. Simply stated, it will cause the company's customers to live above their means.  We all knows what happens when we live above our means for any extended length of time; eventually the house of cards collapses and we go bankrupt.  This method of avoiding rate increases cannot support itself over the long term.

Appalachian Power's proposed legislation is not limited to a one-time occurrence.  It will allow all WV utilities to issue bonds for past, present and future costs instead of raising rates through a standard rate case.  Utility bonds have been issued in the past to pay for capital expenditures on fixed assets, such as scrubbers or power lines.  In that instance, the customers who will finance the bond are receiving the benefit of the asset they are paying for over its lifetime.  They're getting something in return for their payment.  In Appalachian Power's world however, they would like for future customers to pay for current operating expenses, which only provide benefit to the current customers who are receiving the electricity generated by the coal that they can't pay for.  They are asking your children and grandchildren to pay for the electricity you use today.  This is not financially prudent.  In fact, it's stupid.  It also violates the basic premise of regulated rate recovery, which is that the charges you pay are "just and reasonable."  Appalachian Power's lawyers know this, but they are nevertheless setting up this customer-financed Ponzi scheme.

There's a lot of little things wrong with this bill that I won't spend time detailing, because I don't have that much time!  One I will mention -- this legislation will allow the unpaid customer debt to be shuffled among different rate classes for recovery before being financed through the bond.  In other words, they could reassign the substantial unpaid debt of big, industrial electric customers to other classes of ratepayers, such as residential ratepayers, so that industry does not have to pay back their share of the expense that has been financed.

Matheney says, "Without something unusual, we would have to put that in a rate increase this year," she said of the $350 million. "We know that this is something that our customers cannot handle."

This is true.  Appalachian Power's customers can no longer afford to pay for the service they receive.  Something has to be done.  Sweeping the debt under the rug for future generations to trip over is not the answer.  Sensible planning to diversify generation so rising fuel costs can be managed is the answer.  Until that can be accomplished, another reasonable solution has to be found.  Selling debt bonds is not reasonable.  A company that cannot provide a product at a cost that customers can afford to pay is usually headed for bankruptcy.  How about it, AEP?

Seven years ago, in the midst of contemplating policy to encourage investment in the nation's transmission grid, FERC held a series of technical conferences to hear new ideas and opinions.  One such conference, held in Charleston, WV on Friday, May 13, 2005, was entitled, "Promoting Regional Transmission Planning and Expansion to Facilitate Fuel Diversity Including Expanded Uses of Coal-Fired Resources."  One might question exactly what kind of "fuel diversity" was being facilitated by expanding the use of coal-fired resources in 2005, since over 56% of generation in PJM came from coal during the previous year.  However, Joe Manchin, Peabody Coal and American Electric Power were involved in the conference, so don't waste too much time thinking about it.

A transcript of this technical conference is available here.  It's long, but definitely not boring.  There are plenty of arrogant little nuggets spread throughout, documenting political, corporate and regulatory humor about how they were getting things "taken care of" without notice by the electric consumers who would pay for it all.  (Hint:  search the document for the word "laughter" to find the bulk of their little jokes at your expense.)

During this conference, PJM Western Region President Karl Pfirrmann unveiled his plan outlining "the potential for new transmission resources in the region to enhance opportunities for coal based generation to reach eastern markets."  He called this plan "Project Mountaineer."

Project Mountaineer envisioned two or more new transmission "backbone" projects to "enhance [coal-fired] power flows by up to 5,000 MW."

Project Mountaineer's "transmission enhancements included potentially 550 to 900 miles of new backbone 500 or 765 kv transmission at an approximate cost of $3.3 to $3.9 billion. Although a large number, if such costs are spread to all customers within the PJM footprint, the cost to a typical retail customer would amount to only one mill/kwh."

Pfirrman envisioned that PJM's Regional Transmission Expansion Plan could be utilized as a "vehicle" to create a smokescreen to advance these purely economic projects under the guise of reliability.  In the words of AEP's Mike Morris, "...it lends credibility to what you're trying to do." This resulted in power company propaganda telling electric consumers they would be subject to "brownouts and blackouts" unless Project Mountaineer was built.

In response to the profitable opportunities presented by Project Mountaineer, some of PJM's biggest investor owned utilities began proposing transmission projects that fit into the Project Mountaineer scheme, such as Allegheny Energy's "TrAIL" Project and AEP's I-765 Project.

Four projects that fit PJM's Project Mountaineer criteria were eventually selected as part of PJM's RTEP and "ordered" to be built.  They are:

1.  Allegheny Energy's modified TrAIL Project, a 500 kV line, 215 miles long, beginning in Southwestern Pennsylvania and ending in Northern Virginia.  Dominion Resources was "ordered" to build a second, smaller segment of this project in their territory in Virginia.  Estimated cost for this project was $960M.  The sponsors of this project claimed it would relieve some portion of "congestion," which was purportedly costing PJM electric consumers $1.6B yearly in 2006.  Allegheny Energy's portion of the project was awarded a return on equity of 12.7% by FERC.  This project originally included additional project miles in Pennsylvania that were abandoned after the Pennsylvania PUC denied their application.  TrAIL was ramrodded through approvals and built in 5 years, although purchasing approval in West Virginia resulted in millions of dollars worth of "concessions."

2.  Allegheny Energy and American Electric Power's PATH Project, a combination of parts of both original TrAIL and I-765 projects.  The companies formed a joint venture and were awarded an astounding 14.3% return on equity for their investment in the project by FERC.  The 765 kV project was 275 miles in length, stretching from southern West Virginia, across Northern Virginia and ending in Mt. Airy, Maryland, and was estimated to cost $2.1B.  PATH was supposed to save consumers $47M per year in "congestion" costs.  PATH was shelved last year and is currently "held in abeyance" by PJM.

3.  PSE&G and PPL's Susquehanna-Roseland Project.  This 145 mile long, 500kV project, stretches from Salem Township, PA to Roseland, NJ, and is estimated to cost $1.25B.  For its part of the project, PSE&G was granted a 12.93% return on equity by FERC.  PPL is earning 11.68% ROE through their FERC formula rate.  This project was originally proposed with additional segments in New Jersey that have since been tabled due to decreased demand for the project.  This project is supposed to save consumers $200M per year in "congestion" costs.  This project is still waiting for a permit from the National Park Service.

4.  Pepco Holdings Inc.'s Mid-Atlantic Power Pathway (MAPP) was originally proposed as a 230 mile 500 kV project, stretching from a substation in Northern Virginia, across Maryland's Eastern Shore, through Delaware and ending in southern New Jersey.  Small fragments of this project were also awarded to VEPCO, Baltimore Gas & Electric and PSE&G.  The New Jersey and Delaware segments have since been tabled, again because of decreasing demand.  The current project is 152 miles long and is estimated to cost $1.2B and has also been put "in abeyance" by PJM.  MAPP earns a 12.8% return on equity for its owners and supposedly will alleviate $320M in annual "congestion" costs if built.

An attempt to add up the "benefits" for electric consumers in "congestion" cost savings provided by Project Mountaineer cannot be accomplished.  All the different "congestion" savings claims made by these four projects is calculated differently, is at least 5 years out-of-date, and cannot be verified.  In addition, it's not just a simple matter of adding the claimed savings because each project by itself changes the amount of remaining "congestion" and reduces possible additional savings by the other projects.  The nature of "congestion" itself has also changed dramatically since these projections were made.  Due to decreased demand projections, increased efficiency and demand response, and the TrAIL project going into service, the price differential between Western and Eastern PJM that formed the basis for these "congestion cost" claims has nearly levelized in PJM's 2011 RPM auction. 

"In PJM's MAAC area the price of capacity will be $136.50 MW-day, a decrease of about $100 from last year.  (The MAAC price applies to the transmission zones of Baltimore Gas and Electric Company, Metropolitan Edison Company, Pennsylvania Electric Company, and PPL Electric Utilities, Atlantic City Electric, Delmarva Power, Jersey Central Power and Light Company, PECO, Public Service Electric and Gas Company, and Rockland Electric Company.) The non-MAAC region, will pay the RTO price of $125.99, an increase of about $100. This region includes western Pennsylvania, western Maryland, Ohio, Indiana, Michigan, Kentucky and Virginia.
"The convergence of prices between the eastern and western regions of the market is primarily driven by the significant reduction in forecasted load growth through 2014/2015," Ott said.

According to PJM, congestion is now occurring at PJM's borders:  "The trend of an increasing percentage of transmission congestion occurring on facilities at PJM‘s market borders is driven by 1) reduced west to east flows due to a relative increase in coal resource offer prices in the western part of the market and a relative reduction in gas-fired resource offer prices in the eastern part of the market, 2) increased wind resources impacting the western part of the market, and 3) the completion of the 500kV TrAIL Line."  That's because Western PJM's generators are now trying to unload their unneeded product into other RTOs and can't get rid of it fast enough.

In addition, new gas-fired generation is being planned and built near load on the East Coast, further obviating any economic justification for more expensive coal-by-wire from Western PJM.

The savings are an illusion, but the costs to electric consumers are real.  Let's add up the estimated project costs (although actual costs at completion will be much higher).  $5,510,000,000 - that's $5.51 Billion.

Even this staggering figure is an mirage, however.  It's going to cost electric consumers much, much more.  $5.51B is the estimated total of project assets at completion.  Electric consumers will pay these costs back to the power companies little by little over the projects' estimated 50 - 70 year lifespan.  In addition to the annual, incremental pay off of the principal, electric consumers will also pay annual interest on the remaining balance at rates varying from 11.68 to 12.93 percent.  Return is calculated and paid annually.  Electric consumers are also responsible for yearly expenses such as income and other taxes, and operations and maintenance costs.

Let's take a look at how much the power companies have already spent on project assets:

1. TrAIL's rate base (assets) is $921,926,774.67.  It currently earns them a return (interest) of $76,492,872 per year.  TrAIL's annual revenue requirement (the amount you will pay per year) is $129,108,109, which includes the return.  These figures do not include the cost of Dominion's segment of the TrAIL Project, so consider it a very conservative estimate.

2.  PATH's combined current rate base is $139,771,892 and earns an annual return of $13,347,885.  PATH's annual revenue requirement is $23,211,101, including return.

3.  Susquehanna-Roseland's combined current rate base is $131,284,693 and earns a yearly return in the neighborhood of $17.5M.  Revenue requirement is harder to calculate on this one because project totals are split between two different formula rates that also include other projects.

4.  MAPP's current rate base is $74.2M, with a return in the neighborhood of $7.3M.  Again, these are ballpark figures taken from a formula rate that also includes other projects.  The small segments awarded to other partners amounting to around $70M aren't worth looking up, so consider these cost estimates as conservative.

Here are the eye-opening, conservative totals:

Project Mountaineer has already put you in debt to the tune of $1,267,183,359 - that's $1.26 Billion that is earning the project owners a yearly profit of $114.6M.  In return for the substantial price paid by electric consumers in 13 states and the District of Columbia for Project Mountaineer, only one out of four projects is actually completed and delivering electricity, in order to save East Coast ratepayers some fanciful amount of "congestion" costs.

In addition, these four projects have affected, and continue to affect, thousands of directly impacted citizens in Virginia, West Virginia, Maryland, Delaware, Pennsylvania and New Jersey in other ways.

The TrAIL Project required new rights-of-way, which thousands of landowners were forced to sacrifice at "fair market value."  In addition, it devalued thousands of properties in its proximity, for which damages were never paid.  Allegheny Energy contractors destroyed the environment while building the project.  A complaint about the environmental damage is still pending before the West Virginia PSC.

The Susquehanna-Roseland project has been "filibustered" by the federal Environmental Impact Statement and its owners are now offering a $40M "mitigation" concession to the National Park Service in exchange for a permit.  The cost of any concessions will be added into the ultimate cost of the project that ratepayers must repay to the companies.

MAPP continues to contract for long-term supplies, such as the underwater cable needed to cross the Chesapeake Bay, that may never be needed!

In addition, Project Mountaineer has cost thousands of landowners and project opponents hundreds of thousands of dollars in legal costs to intervene in state permit cases in order to protect their interests.  National non-profit organizations, such as The Sierra Club and EarthJustice and Virginia's Piedmont Environmental Council, have also spent heavily on legal costs to participate in permit cases in 6 different states.  And then there's the day-to-day costs of grassroots citizens' opposition groups that have formed to oppose the four Project Mountaineer transmission lines.  Although the cost of grassroots public relations campaigns are an incredible bargain when compared to the ratepayer funded PR campaigns of project owners, they still rely on donations from affected and sympathetic citizens.

I'd be remiss if I didn't mention the indeterminable societal costs imposed on millions of people who are affected by the increased pollution and destruction of their environment caused by increased mining and burning of coal.

Project Mountaineer is an embarrassing faux pas on the part of both PJM and FERC that should now be retired to the annals of history, along with other politically gauche misconceptions spawned by corporate greed.  The sheer cost of it alone, at a time when electric consumers can least afford it, is not sufficiently offset by any illusory "benefits."  It's time to cancel the remaining three Project Mountaineer transmission lines and move forward with new, smart energy policy.

Pam Kasey did a great article about the PATH Formal Challenge in today's State Journal.  Easily one of the brightest and most knowledgeable reporters I have been interviewed by regarding the Challenge, Pam also asked the most pointed questions.  She spent a little time reading some of the background documents and investigating before calling.  She's a shining example of true investigative journalism.

I love the way she ended with my favorite quote from PATH's Answer.  Yeah, Randy, we'll see just who "fails to grasp the distinction between efforts to influence decision makers during the process of obtaining approval to construct a transmission project, and broad-based activities and distribution of information intended to educate government officials, business and community leaders, and the public at large...," won't we?

The Wall Street Journal reports that FirstEnergy could profit more than $200M from the closure of 6 of its old, coal-fired plants announced last week.

As reported earlier, this is a business decision intended to make more money for FE's stockholders.  Too bad, so sad for the 500 employees who will be in the unemployment line, and also for the towns who depended on these plants as as economic engine.

You'd think that a few of those millions could be parted with to set up programs to ensure that affected employees were given opportunities for equivalent jobs elsewhere, or given the benefit of retraining for equal jobs in another area of the energy industry, such as the booming renewable energy sector.  Transition programs for the affected localities could also be instituted.  Instead, FE is absconding with all that happy cash.

One word.  Karma.

AEP subsidiaries are "selling" assets to each other in another corporate shell game.  This article says that AEP-Ohio will be selling generation it owns in WV to fellow subsidiary Appalachian Power.  Meanwhile, they fired up their new gas-fired plant located in Ohio, which will be paid for, at least in part, by Appalachian Power customers in WV.  Confused yet?  AEP hopes so!

In this article, the reporter was treated to an explanation of AEP's "power pool" (probably because she asked tougher questions).

What's in neither article is the promised merging of AEP WV sudsidiaries Appalachian Power and Wheeling Power, which was promised to the WV-PSC in AEP's last rate case.

Why all this confusion?  Because Ohio is deregulating generation and AEP is trying to keep their costly generation behemoths in a regulated environment.  In a deregulated, or market-based, market, costly upgrades and other costs of running these plants are wrapped into the cost of the generation bid into market.  In a regulated state, these "extra" costs are covered by ratepayers of subsidiaries who "own" these assets.

Bottom line:  It's all about AEP making even MORE money at your expense!