Don't you just love the internet?  You can find just about anything on here, including tons of embarrassing history, if you know how and where to look.

Recently unearthed from the beyond the grave, here are the comments of PSEG on the DOE's NOI on National Interest Electric Transmission Corridors.  Apparently PSEG was rather tweaked at the comments PJM filed in which they asked for an early designation of two corridors needed for the TrAIL and PATH projects, along with similar comments by AEP and Alleghey Energy, promoting their own projects.  I'm not going to over analyze this for you.  Read it for yourself.  I guarantee that you'll enjoy it!  Here are a couple of tantalizing excerpts:

"...PJM has failed to furnish sufficient evidence to  support this claim and has in fact presented an apparently biased and incomplete view of the facts."

"Thus, it is not clear what “problem” the AEP and Allegheny projects are intending to address.  By extension, there has been no detailed cost-benefit analysis comparing the “benefits” of the AEP and/or Allegheny transmission projects with the “costs” of the congestion the projects are intended to relieve.  Moreover, PJM clearly has ignored the timing inherent in the RTEP process by simply skipping past the one-year market window and moving right to a regulated transmission owner-proposed transmission “solution.”

Isn't it funny... despite hitting it dead on in their comments, PSEG's "concern" seemed to evaporate after they were handed the Susquehanna Roseland lollipop.

I've been trying to plow through FERC's Order No. 1000 that was released last Thursday, but with all the other things I've got going on right now, it's not going to happen anytime soon.  Therefore, here's what I've gleaned from it in the little time I had available.  All the news reports so far have been disappointing.  None of these reporters have actually read Order No. 1000, but are depending on the CliffsNotes version provided by FERC's press release and the statements of the Commissioners.  I'd be an idiot if I was satisfied that these stories provided all the details I needed to decide if Order No. 1000 was a good thing or a bad thing (or somewhere in between).

Bill has a pretty good general overview over on TPL.  This is his initial reaction to the order, and it echos mine as well.  While it appears that this order is going to work against the PATH project, it's encouraging AEP's "national grid" fantasy.  FERC believes we need a whole bunch of new transmission lines hundreds of miles long to pump western renewables to coastal population centers and to increase long distance energy trading (Enron?  Hello?).  As you all know, spending billions to transport power hundreds of miles, when local renewables that don't require new transmission lines are available, is inefficient and uneconomic.  Off-shore wind is located within 10 miles of population centers, and I read something recently that said existing transmission networks can handle the additional power generated by off-shore projects.  Instead of the east coast's power traveling from the west, it should come from the east.  Of course, that would spell disaster for our coal-burning buddies, wouldn't it?  Heh, heh, heh!!

FERC states that their new transmission planning and cost allocation order will "...benefit consumers by enhancing the grid’s ability to support wholesale power markets and ensuring transmission services are provided at just and reasonable rates."  However, think about it while applying a little logic.  FERC is promoting billions of dollars worth of new transmission infrastructure (plus incentive payoffs to the energy companies) that needs to be paid for.  It's going to be paid for by YOU.  The first place I went in Order No. 1000 was the Commission Determination on their new cost allocation process.  Here are the six new principles of cost allocation:

1. Costs are to be allocated to those who benefit roughly commensurate with identifiable benefits received.  Some of these benefits are:  reliability & sharing reserves, production cost savings, congestion relief and meeting public policy goals.  Sounds great, doesn't it?  However here are a couple of things that bug me.  First, FERC prattles on about the "benefits of an interconnected transmission grid."  Scared yet?  Here's another:  In determining "benefits," power companies/RTOs can use "likely future scenarios."  To quote the Order, "Scenario analysis is a common feature of electric power system planning, and we believe that public utility transmission providers are in the best position to apply it in a way that achieves appropriate results in their respective transmission planning regions."  Now you're crouched in the corner doing some primal screaming, aren't you?  That's right, they can make up some fictional "scenario" whereby you might "benefit" from their project and assign you costs NOW.  That sounds fair, doesn't it?
2. No involuntary allocation of costs to non-beneficiaries.  A beneficiary is one who causes costs, or benefits from the facility (transmission line).  No, this doesn't mean you can refuse to pay your electric bill, this is all going on between the power companies, the RTOs and FERC.  Nobody cares what you think, little ratepayer stakeholder.
3. The benefit to cost ratio for selecting projects by an RTO cannot be higher than 1.25.  This means that your "benefits" must be at least .25 higher than the cost of the project that is selected.  However, this is no guarantee because this principle is merely intended to ensure that RTOs don't set too high a threshold for competing projects.  I just can't wait to see what kind of "PATH MATH" (lying with numbers) turns up in these benefit/cost ratios.
4. Costs cannot be allocated to another region without voluntary agreement. (Again, not YOUR agreement, silly!)
   
5. The method for determining benefits/beneficiaries must be transparent and provide adequate documentation that will allow stakeholders to determine how it was applied.  (Again, you're not a "stakeholder"!)
6. Different cost allocation methods may be created for different types of facilities (projects):  Reliability, Congestion or Public Policy.

A "public policy" project is driven by individual state (or federal if that ever happens) Renewable Portfolio Standards.  So, say Maryland needs additional renewables to meet their RPS.  PJM will want to build a gigantic new transmission line from the midwest to bring wind power to Maryland, because we know transmission is the PJM-preferred solution to EVERY problem.  It wouldn't matter if Maryland is planning to construct their own in-state renewables or hook up to the Atlantic wind backbone, PJM would propose a transmission line.  Said transmission line would traverse several other states on its course and "benefit" people along the way.  That way, laws being enacted in the state of Maryland by Maryland legislators will also affect citizens of other states who had no say in their creation.  Landowners in these other states will also have their property taken by eminent domain to satisfy Maryland's laws.  Kind of sticks in your craw, doesn't it?  I expect to see this one in court in the near future.

Anyhow, that's only the tip of the iceberg.  I'm sure there's lots more goodies in Order No. 1000 I haven't gotten to yet.  I hear there's some "backstop" provision in the planning section that will cause an evaluation of alternatives in the event of a stalled project.  Sounds good... probably will end up being bad, but that's fodder for another day when I find the time to finish reading Order No. 1000.  My advice... get yourself off the grid ASAP!  That's where I'm heading and I hope you join me in my monthly giggle-fest when I don't get a whopping electric bill that pays for Mikey's "national grid."  If we make our off-the-grid club big enough, there won't be anyone left to pay for the national grid and all the power companies left holding the bag will go belly-up.  You don't have to finance this ludicrous expenditure.  Your own power generating system is within your grasp.

In other news:  Today the WV PSC Consumer Advocate Division filed a scathing rebuttal to the power companies' answers to the Staff's Petition to require a report of the condition of their transmission systems in our state.  Bill has the scoop here.  I'm trying to decide what my favorite part is.  Initially, I got a kick out of how he lambasted PJM for their bias, but maybe that's only because I was right at the point in the draft of StopPATH's Transmission Incentives NOI comments where I call PJM a cartel...  That Transco thing was pretty good too...  What's your favorite?

And speaking of Transmission Incentives comments to FERC, are you working on yours?  They are due a month from today, so get busy!!  If you need help, go here.  As you can see, FERC needs a little consumer education from the consumers and it appears that this NOI is actually a spin-off from Order No. 1000.  Get writing, folks!

And finally, go check out Bill's analysis of what's going on with PJM's strawman planning process.  Thanks, Bill!  One less thing for me to do!  As he points out in his post, The Sierra Club, Piedmont Environmental Council and EarthJustice are acting on our concerns at PJM.  So, if you're a PATH opponent who is wondering what to do with your money now that the project is stalled and we're no longer funneling all our spare cash to a lawyer and experts, why not show these organizations a little love of the green variety?  Bill's got his comments turned on now -- you can post a comment (unless, like me, you suddenly find yourself speechless).

And last, but not least, come check out what's going on at the Coalition for Reliable Power.  We're planning a series of public meetings next month intended to empower "Potomac Edison" customers to improve that farce of an energy efficiency program they proposed in WV.  Hope to see you all there!

And now I'm going to go crawl back in my hole and get back to work on all these rotten projects sitting on my desk.  Thanks, PATH, you're a real PAL!

Today, the staff of the West Virginia Public Service Commission has filed a Petition to Reopen to Implement and Expand Certain Commission Ordered Conditions Expeditiously.

To boil it down, the petition asks that the Commission order AEP and FirstEnergy to submit a plan for upgrading their transmission infrastructure in this state, particularly FE's Pruntytown-Mt. Storm 500kV line, within 30 days.

The Pruntytown-Mt. Storm line (we call it PMS, because we think the name fits!) has been identified as an impediment to power flows by PJM for years and was also singled out for re-build by Dominion in their plans for alternatives to the PATH project.  PMS is over 40 years old and the Petition relates that it recently went off line due to equipment failure, and the outage did not produce transmission problems.  Staff Attorney John Auville correctly points out that now is the time to rebuild and upgrade the aging fleet of high voltage transmission lines in West Virginia because we are currently in a time window of lowered demand.

The citizens of West Virginia worked together with our legislators to ensure passage of HCR 149 during the past legislative session.  HCR 149 urges that the West Virginia Public Service Commission act to review the condition of the Pruntytown to Mt. Storm 500kV transmission line owned by Monongahela Power, a subsidiary of FirstEnergy, and order the rebuilding and reconductoring of that transmission line as soon as is practical.  Today's Petition is the fruit of our labor.

What I find incredibly compelling is that while Mt. Storm-Doubs is in the process of being rebuilt, PMS failed, and the transmission grid didn't miss a beat.  There were no massive blackouts or brownouts.  We didn't all start setting up housekeeping in caves or historically regress in any way.  The power companies and the PJM cartel has been pulling our leg about the dire need for additions to the transmission system.

As an added benefit, the rebuilding and modernizing of existing transmission lines can be accomplished faster and cheaper than building new transmission lines such as PATH, and rebuilds do not require the taking of private property by eminent domain.  This is an incredible step in the right direction by West Virginia!

We've all been praising the state of Virginia for putting conditions on a re-filing of the PATH application, but I think West Virginia is going to push them out of the top spot with the best post-PATH move, but only if the Commission approves the petition.

Take a moment to send your comments regarding this matter to the WV Public Service Commission.  You can send your comments via mail, fax or through the PSC's new online comment system.  Address, fax number and the online comment form can be found here.  Be sure to mark your comments with WV PSC case numbers 07-0508-E-CN and 09-0770-E-CN.

And come on over to the Coalition for Reliable Power, where we've been advocating for the rebuilding and modernizing of existing transmission infrastructure, and join us as a member and share your ideas about reliable power.

We all know how much effort PATH's land agents put into getting purchase options signed by landowners.  It was of such great importance that land agents used every tool of lying, harassment and coercion in their arsenal... to the tune of millions of dollars a year. 

Now, PATH is releasing those options and any and all claims to the properties and rights-of-way necessary to construct the project.  If PATH is re-incarnated, they will  have to begin all over again acquiring necessary properties along their proposed route.  You know what they say... fool me once, shame on you; fool me twice, shame on me!

The lil' CoalFella got a nasty surprise yesterday when he received a phone call from a reporter inquiring about the release of options.  Investigative journalism is not dead after all!  In this article in The Journal, lil' CoalFella sputters and spins like a small plane that's run out of gas and is preparing for an emergency landing.

Refusing to admit the truth (for once!), and continuing to pretend that the project is still going to happen continues to burden landowners with the requirement to disclose the potential of the PATH project if they try to sell their properties.  This makes their properties worth a lot less and many have taken a huge financial hit when circumstances have required them to sell their property over the past three years.  Properties in or near PATH's proposed right-of-way are virtually unsalable.

The way the option contracts are structured, PATH would have made a series of three payments to landowners who signed them.  Initial payment (the amount of which is individually negotiated) is paid to the owner at signing.  Another payment is due at the mid-point of the contract period (again, negotiable).  The final payment, which when combined with the previous two payments will equal the negotiated "fair market value" of the property, is due when the option is exercised and PATH takes legal title to the property.  PATH has made the initial payment for options on record, and in some instances has made the mid-point payment to continue the option.  That's capital they have invested in the project and upon which ratepayers will be paying 14.3% return yearly for many, many years.  Now, for some of the options, PATH is failing to make the mid-point payment when it comes due and choosing to release the option instead.  If PATH is re-incarnated and given the green light by PJM later this year, they will have to re-negotiate and coerce property owners to sign a new option, and start back at square one with another initial payment due at signing.  In the long run, if PATH actually intends to construct the project in the future, it would have been cheaper to make the mid-point payment and continue to hold the option.  PATH did not do this.  Either they're intending to unnecessarily spend a lot more capital reacquiring options, or they're just done and will not pursue the project (or the options) in the future.  Which one do you think makes sense?

"Maintaining the project in its current state" would include continuing to hold the land necessary to construct it.  To release claim to the land makes it harder to construct the project in the future.  The PATH project is regressing, instead of maintaining itself or progressing.  Ooops!  Looks like PATH is not following PJM's directive after all.

In his uncertain ramblings, the CoalFella tells us that it's all about maintaining some pretense that the project is still alive at FERC.  Yes, PATH, we know you're in a serious world of hurt at FERC right now and are trying to pull the wool over FERC's eyes.  It's not working.

To quote our pal Randy Palmer, "When are you people just going to give up?"  The writing is on the wall and release of options isn't the only clue I've got that PATH is heading for abandonment.  Let's not continue to play this game.  Do something honest for once.  Abandon the project!

Virginia has dismissed the PATH case as per Hearing Examiner Skirpan's recommendations (which means with conditions for refiling).

PATH has also filed the documents the Commission required for withdrawal  If you want to see them, ask, but I'm not posting them because they're gibberish.  Case closed.  Read more at TPL.

We're done here, PATH.  It's time to file for abandonment and go away for good.

Look what I found tonight while poking around in some old files!

Ding-Dong!

Sadly, it's still just as appropriate now as it was over a year ago.

Isn't it time for PATH to give up yet?

According to documents I obtained through the Freedom of Information Act, the PATH Companies have submitted an official request to the National Park Service and U.S. Forest Service to hold their application for rights-of-way to cross parks and forest in abeyance through December 31, 2011.

The NPS advises that they are, "in the process of reviewing the applicant’s request and that a decision is pending soon on the abeyance."

Let's take a look at PATH's request for abeyance.  They aren't telling the NPS the whole truth, but a sanitized version of "facts" that suit their agenda.

They perform the same song & dance about PJM's "suspension" and the unknown nature of need for PATH, and they make the following statement:

"PJM informed the PATH Companies that it plans to complete its further analysis of the PATH Project
by late 2011."

PATH didn't tell the NPS about the PJM analysis that they presented to the Virginia SCC on the same day this letter was written (see attachments to Sierra Club's letter).  That analysis showed that PATH will not be needed within the next 15 years (2026 or later).

They also don't tell the NPS the truth about what's going on at FERC.  They mention that they have advised FERC of the suspension and pretend everything is hunkey dorey.  NPS may not be aware that the issue of PATH's "suspension" at FERC is being contested by numerous citizens, The Sierra Club, and a U.S. Congressman.

PATH also reveals the new EIS contractor, PBSJ.  Post, Buckley, Schuh & Jernigan has recently merged with a company named Atkins Global.  PBSJ also has a glaring conflict of interest because they have previously worked for AEP on their Morgan Creek-Comanche 345kV transmission project in Texas.  (Ooops, looks like Atkins Global has taken incriminating evidence offline, but don't worry, I already have it).  :-)

In addition, the VA-SCC Hearing Examiner's report in the matter of PATH's withdrawal in that state recommended that another application contain a completed 2012 RTEP.  That cannot happen until at least first quarter of 2013.  PATH's letter to the NPS claims the route of PATH will not change.  Therefore, PATH's NPS "abeyance" will have to continue until then, creating a 3 year delay in the EIS process.  A lot of new information will be available in 3 years.  The EIS should rightfully start from the beginning, with a new round of public scoping meetings so the affected public will not be disenfranchised by corporate delays.

Since the NPS is still reviewing PATH's request, feel free to submit your own comments to Morgan Elmer at the NPS.  Please keep your comments respectful, helpful and informative, as they will become part of the public record in this case.  The NPS needs to consider all the information that PATH is withholding from them when they make their decision.

Looks like AEP finally took some good advice after Mikey's public PATH tantrum a couple weeks ago and has finally relegated him to cardboard cutout status.  Maybe AEP will invest in a Popemobile for Morris and just drive him through all future financial presentations, where he can smile and wave and not do anymore damage, until they finally put him out to pasture in November. 

At yesterday's Deutsche Bank's Alternative Energy, Utilities and Power Conference, they replaced him with Nick Akins, AEP's CEO-in-waiting.

So, what did AEP have to say for themselves at the conference?  The pie charts on Slide 4 epitomize AEP's problem.  Their generating capacity is 65% dirty, stinking coal, however actual production was 82.5% coal.  That's a lot of increasingly expensive coal pollution.  Compare that with the U.S. average of 30% capacity and 45% production.  AEP has twice as much coal as the average U.S. power company. 

Slide 6 shows the disparity between eastern and western AEP's coal-fired resources and also displays the age and condition of their pollution belching monsters.

Slide 7 details pending EPA regulations, the dark cloud on AEP's financial horizon.  Check out the note at the bottom.  This is where AEP starts whining like a true milksop champion,  "The cumulative effect of the proposed rules is not achievable in the allocated timeframe."  And do you know why that is?  It's because AEP sat on their butts for years in complete denial and refused to clean up their act, while other energy companies were planning ahead in order to meet looming deadlines.  Wahhhhhhhh, AEP, WAHHHHHHHH! 

Slide 8 whines about "infeasible construction timelines".  Guess what AEP?  Lack of planning on your part does not constitute an emergency on our part!  Suck it up and quit your pathetic mewling -- nobody cares!

This is why environmental organizations have been asking AEP, "What's your number?"  How many American lives will AEP sacrifice while they try to enact legislation to delay clean air standards?  AEP, you're detestable!

Slide 10 is pretty funny... here are your "Key Takeaways."  This is what AEP wants you to think, when reality is that AEP's predicament is entirely their own fault through poor planning and greed.

Now, skip down to slide 26 (not that the ones in between are completely uninteresting, look if you want).  Notice how capital expenditures for transmission completely disappear in 2012?  Looks like it's all going to be part of their "AEP Transco", which practically doubles, by then.  Got some plans you want to tell us about, AEP?  Slide 31 tells us about AEP's Transmission Investment Strategy.  "Mid-term investment" details their Transco plans, and "Long-term investments" are joint ventures such as PATH.  According to AEP, these projects have, "forward looking formula rates, reasonable ROEs and FERC incentives."  Reasonable?  Hah hah hah!  We'll see about that when your PATH ROE is finally settled, won't we?  The best part of this slide is the note at the bottom, which states:  "Transmission has a diversified investment approach that positions it as one of the key AEP growth businesses."  Yeah, we know.  It's all about the money, isn't it, AEP?  You greedy bastards!

Slide 34 (the last slide) is the best one.  Notice that the PATH project does not appear in the list of joint venture projects in PJM?  That's because PATH is DEAD.  It was a stupid idea to begin with and grassroots opposition has kicked it to the curb.  Give up, AEP, PATH is NEVER going to happen.

Oh, wait... it looks like Mikey has escaped from his Popemobile today and run his mouth again.*  Here's a hint for the AEP geniuses:  Put the lock on the outside of the door so he quits escaping and making you look even worse!

*Speaking of it being "all about the money," it looks like WSJ stuck Mikey's comments behind a pay wall.  For your reading pleasure, here are the article's Mikey quotes:

AEP CEO Mike Morris called the EPA's existing timeline a "train wreck" precisely because a surge of shutdowns would create grid reliability problems and hurt the economy.

"We can get everybody to where they want to go environmentally by 2020," Morris said.

AEP estimated that EPA regulations would cost it between $5 billion and $11.2 billion depending on the timeline and the scope of the rules that are implemented. These costs would be passed on to AEP's utility customers in the form of higher rates.

AEP CEO Michael Morris told a couple of whoppers during a recent earnings call.  Maybe he did it knowingly because he was trying to save face with investors about the failure of their PATH Project; or maybe he did it unknowingly because he has no clue what's going on at his own company.  Whatever the reason, neither one of the AEP executives backing him up bothered to correct him.  So, what does this say about the moral climate of AEP?

AEP's "Principles of Business Conduct - The Power of Integrity" can be found here.  However, if Morris would remain uncorrected while misinforming analysts about the state of AEP's affairs, does that mean that these principles are mere window-dressing?  Or do they simply fail to apply at a certain level of AEP's hierarchy?  Is Morris setting the right example?

Let's take a look at some of AEP's principles and see how they have been applied to the PATH Project over the years.

Page 1 contains a Message from Mike Morris:

"Every day we demonstrate our commitment to excellence by the way we live and work according to our shared beliefs about the way we will treat each other, our customers, and the communities we serve."

I don't know how they treat each other, but the way they have treated their potential customers and the communities they intended to serve with the PATH project has been abysmal.  The PATH Project has been one huge lie ever since its inception.  PATH is not needed (finally admitted by PJM), and relied heavily upon a dishonest PR spin campaign and influence buying to facilitate necessary approvals.  I have never encountered an affected "customer" in PATH's "community" who didn't feel that they were being lied to and bullied by PATH and its land agents over the past several years.  PATH has also been hugely expensive to the ratepayers collectively financing it, and personally expensive to the citizen opponents who have expended a great deal of time, effort and money over the past three years in order to defend themselves and have a voice in the approval process.

More from Mikey:

"Ethical conduct means doing the right thing at the right time, every time. It means applying our core values in all our business decisions. It means adhering to the laws, regulations, and policies related to the performance of our jobs. And, it means demonstrating our leadership, integrity, and compassion as a valued corporate citizen of every community we serve. We all share responsibility for maintaining the power of AEP’s integrity."

Did AEP "do the right thing at the right time" when their greed got the better of them during The Transmission Project Development Renaissance -- Siting Investment Post EPACT 2006?  (Page 3 - Look!  There's our pals Haney, Poff and Herling!)  No, they didn't.  Their I-765 project was just too much, too late, to slip past a public that was well-prepared to deal with it, unlike the TrAIL project that Allegheny Energy and Dominion managed to slide through approvals with bribery and illegal backdoor political deals.  We were ready for you this time!  AEP's wrong decision at the wrong time has already cost PJM's ratepayers over $100,000,000, plus 14.3% interest yearly.

Did AEP demonstrate integrity and compassion in our community when their land agents tried to get landowners to sign option agreements without the advice of a lawyer?  This begs the question:  Would Mikey and his henchmen sign a property purchase agreement or option on their own real estate without the advice of a lawyer?  I doubt it.  I don't think Mikey is allowed to fart without the prior advice of AEP's legal staff.

Now let's get to the Principles:

Our Mission
Our mission, simply stated, is bringing comfort to our customers, supporting business and commerce, and building strong communities.

Was having PATH hanging over your head for the past 3 years comforting to any of you citizens?  I will say that PATH strengthened our communities though -- it brought us all together against a common enemy like no issue in recent memory.  The PATH opposition came from diverse backgrounds and varied political persuasions, but yet we were all able to work together effectively to stop PATH.

Our Values

Justice & Fairness
Doing the right thing at the right time, every time.
Trustworthiness
Cultivating a reputation of honesty and straightforward
communication.
Responsibility
Accepting accountability for your actions and living up to high ethical expectations.
Citizenship
Developing a sense of community among all those you encounter.
Respect
Treating others the way we want to be treated, regardless of position, and valuing each person’s talents, perspectives, and experience.
Caring
Maintaining a sincere desire to make the world a better place.

We've already covered that "right thing, right time" thing, so let's skip to AEP's trustworthiness.  After nearly 3 years of being lied to, who trusts AEP?  Anyone?  AEP's reputation is one of a dishonest, greedy, uncaring corporation, and they fully earned it.

Accountability - now is the time for AEP to admit that their PATH project is never going to happen.  They made a mistake with the project, now they need to pull the plug and quit trying to "suspend" their project and hoping that PJM can come up with another excuse to build it.

Citizenship - AEP is an outsider in our community, and always will be.  We realize a corporation is not a person (no matter what the courts told corporations) and has no guilt, compassion or any emotions of any kind.  A corporation makes money, not warm fuzzies.  A corporation doesn't "care" about anything except profits.

Respect - Is that what Archie "Creepyfreak" Pugh was practicing when he spent multiple hearings, in the words of Patience, "staring at us like a stinkbug on his shoe?"  Further, when has PATH ever "respected" any of us?  Examples demonstrate that AEP was never respectful of the opposition:  Castigating, demeaning legal filings; making jokes to each other about "the people around here" at a Tucker County public meeting; dismissing all our concerns as insignificant "NIMBY" issues, both directly by PATH personnel and through PATH's use of third party front groups to discredit opposition to their project.

Caring - see Citizenship above.  Also, ask yourself this:  Does a gigantic substation in the middle of 1350 homes and the destruction of thousands of acres of forest, farmland and suburban homes, for no other reason than to provide corporate profit, make the world a better place?"

Relationships With Customers
A key to AEP’s business success lies in our ability to please our customers by meeting their needs in ways that improve their quality of life. This includes delivering safe, efficient, and reliable services of consistently high value and promoting our products truthfully. If we please our customers, we will please our regulators, our financial results will reward shareholders, and our employees can reap significant rewards. AEP depends on long-term, continuing relationships with satisfied customers.  Cultivating a reputation of honesty and straightforward communication is fundamental to this long-range approach.

PATH does not meet our needs; it meets AEP's need to make money.  PATH does not please us.  I think we have made that abundantly clear to AEP over the years.  Living with the stress of the possibility of losing our homes, our investments, our health and that of our children, for nearly three years did not improve our quality of life.  It caused sleepless nights, gray hair and denied us any form of true relaxation... for year upon year.

PATH is AEP's "product."  They did not promote it truthfully.  They promoted it by attempting to intimidate us, and through a PR spin and propaganda campaign that they made us reimburse them for.  We are not pleased with AEP.  AEP's "regulators" aren't too happy with them either because PATH wasted a huge amount of their time and resources on a project that was never needed.  AEP's reputation is one of dishonesty and evasiveness.  Our "relationship" with AEP has gone on much too long already.  Go away, AEP, and let us get on with our lives!

Each employee and officer should deal fairly with our customers, suppliers, competitors, and employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.

Wow!  PATH's land agents coerced land owners into signing legal agreements without the advice of an attorney, manipulated them to get those options signed, and misrepresented material facts about need, safety and the effect of their project on our communities and finances.  Nothing was fair about waking up one morning and finding your whole life turned upside down because a corporation had decided to drop a high voltage power line in your backyard.  We paid all PATH's legal costs, and then we had to pay our own legal costs as well, or we wouldn't have been fairly represented in the legal process -- nothing fair about that either.

In general, the antitrust laws prohibit:
• Joint action, by means of conspiracies, agreements and other understandings between two or more competitors regarding prices, customers, territories, and other policies or conduct that unreasonably restrain competition.
• Unilateral action that is exclusionary and tends to create or maintain monopoly power in the marketplace for some particular product or service.
• Discrimination in the prices to buyers of similar goods, who are similarly situated, during the same market conditions, subject to several complex defenses and conditions.

How about AEP & Allegheny Energy entering into a shell company "partnership" to construct a completely unnecessary transmission line in order to ship the electricity they produce to customers hundreds of miles away who will pay more for it?  On top of that, there are millions of ratepayers who derive no benefit from PATH that will be paying for it for years.  And then there's the matter of those PATH alternatives that were proposed by others and rejected, with bias, by PJM.  Did AEP have a hand in that?

• False or misleading advertising that either disparages a competing product or service, or conveys materially misleading information about our own product or service.

Remember this one?  "Our nation's power grid system is at risk.  Five years ago, the blackout in the northeast was a warning."  The northeast blackout was caused by human error on the part of FirstEnergy and lack of transmission line maintenance that caused a line to sag into a tree that shouldn't have been there.  That has nothing to do with building additional transmission lines.

Or how about this one?  "The new PATH transmission line is not just a bright idea for our region but for communities and neighborhoods along the way.  From West Virginia to Virginia and Maryland...it's one PATH but it leads everywhere... bringing safe, reliable power to our communities... making sure industry has a dependable source of energy to count on... and giving our local schools, hospitals and offices the energy it takes to stay up and running.  Best of all, the PATH transmission line will be there to ensure dependable energy for the future.  Not only reinforcing our power grid... but ready and able to support new energy sources, including renewables."  PATH was a transmission line.  It was not part of the distribution system and did not bring power to the communities along the way.  It was a highway plowing through our communities on its way to the east coast, with no local exit or entrance ramps for our use.  PATH originated at AEP's John Amos coal-fired power plant and was designed to carry coal-by-wire, not renewables.

And then there were the ads that started out, "Despite what you may have heard.." that intended to disparage the opposition's message.

I would consider all of these examples to be misleading, and there are hundreds of others.  PATH bombarded the public with misleading advertising, and recovered the cost of this misleading advertising from the same public.

AEP is committed to nurturing strong and productive relationships with our public officials and regulators. Employees must conduct Company business before public officials and regulators openly and honestly, exercising the utmost integrity at all times. When in doubt on any ethical question, always choose the highest standard.

The Company recognizes that major corporate issues can be at stake in the political arena and maintains a public policy program to advocate the Company’s positions on these issues. Such advocacy often involves
communication with elected officials. However, the Company will exert no pressure, direct or indirect, to influence decisions of employees who serve in public positions.

The PATH Companies engaged in a federal, state and local lobbying effort that was intended to unfairly influence approvals for their project.  PATH also recovered a portion of this lobbying expense from the ratepayers, in violation of FERC rules.  When asked to produce documents in discovery related to their lobbying campaign, PATH refused to be open and honest and had to be ordered by the WV-PSC to produce detail of their lobbying account.  There are still many unanswered questions about PATH's lobbying efforts.  Does AEP want to answer them now, in their spirit of openness and honesty?  I doubt it.

Accurate Accounting
The Company’s records, books, and documents must accurately reflect all transactions and provide a full account of the organization’s assets, liabilities, revenues, and expenses in order to accomplish the above and to comply with related laws and generally accepted accounting principles.

Two words:  Formal Challenge

Security of Property and Confidential Information
All employees must protect the Company’s and third parties’ confidential information and prevent the information from being improperly disclosed to others inside or outside the Company.

The PATH Companies made some serious mistakes in this vein during discovery on the 2010 Annual Update.  AEP staff and PATH's counsel released this.  I'm only displaying the cover page of the document as an example, and not the confidential document it was attached to.  PATH counsel then turned around and asked me to sign a protective agreement for this very same confidential document, after it had already been released to another party without benefit of an agreement!  PATH counsel also released the personal information of a third party, one of their contractors.  We didn't ask for, or want, the confidential information we received.  I'm not going to go into any more detail on this.  Randy knows what he did.

AEP’s aim is to please the customer by meeting their needs in ways that improve their quality of life. That means giving one kind of service to everyone … the best possible.

Living in close proximity to a 765kV high voltage transmission line does not improve our quality of life.  It detracts from the quality of our lives, and puts our actual lives in jeopardy from constant exposure to EMF.  In addition, AEP's plan for approval and construction of PATH wasn't the best possible.  There are a multitude of other ways to attempt to accomplish the same goals that don't rely on dishonesty, intimidation, and influence buying.  We hope we have taught AEP some things about their processes along the way.

Realize organizational integrity – walk our business ethics talk.

Mike Morris certainly didn't walk the talk when he misled financial analysts during an earnings call.  AEP's CFO and Treasurer didn't walk the talk when they let the misinformation go uncorrected.  My conclusion is that AEP doesn't walk their talk, which renders their Principles of Business Conduct nothing but worthless talk.

Put simply, our reputation is earned by our conduct. Unfortunately, the actions of one individual can damage the reputation of all. Since perception is often
reality for our customers and other stakeholders, we must take care to guard our reputation by acting with integrity in everything we do.

Well said, AEP.  Your corporate reputation has been sullied by your lack of integrity regarding the PATH project, and the disgraceful way you treated affected citizens during the process.  Because of the immortality of the Internet and our success in this David vs. Goliath battle,  AEP's reputation of dishonesty will be a weakness that haunts them for a long, long time.  The PATH opposition has created a new paradigm in successfully fighting greedy corporate initiatives that will be referenced by those who come after us time and time again.  Those who don't learn from history are doomed to repeat it.

It looks like the love affair between AEP and the former Allegheny Energy may be over.  Our star-crossed lovers have now begun to attack each other.  What's going to be left when they're done rolling around on the floor and pulling each other's hair?

The latest volley was lobbed by AEP on Monday, when they petitioned to intervene out of time in the TrAIL abandonment case at FERC.  However, this was only the latest provocation in an escalating battle.

On February 25, the FirstEnergy/Allegheny Energy merger was finalized.  Allegheny Energy found themselves a new sugar daddy and cuckolded AEP.

On February 28, PJM announced that they were "suspending" the PATH project.  Word is that FirstEnergy wasn't interested in taking on any red-headed stepchildren like the PATH project.  At that time, AEP's CEO reacted by whining, "We remain convinced that the project will be needed and plan to move forward with it when PJM completes its review."

On April 21, AEP's CEO threatened to, "move forward on that project, with or without our current partners."

Meow!

It was really only a matter of time.  Despite their "good buddy" public faces, these energy corporations are competitors and will gladly stab each other in the back when it suits their purposes.  It's all about the money!  Remember what happened when Dominion got interested in offshore wind and proposed four alternatives to the PATH project last year? 

Fight on, fellas!  We'll be sitting here making like the Byzantines.  Because we're smarter than you.