Impact on Need for New Long-Distance High Voltage Transmission Reduced load growth estimates means transmission expansion needs to be focused locally based on specific load growth; need to consider off- peak energy usage (electric vehicle charging) in ratings for equipment

In areas like PJM, where a states are pursuing off-shore wind, need transmission to (1) interconnect off-shore wind; and (2) develop network to provide optionality to deliver future off-shore wind efficiently

Off-shore wind is alternative to very long distance transmission to deliver western wind, which are not part of public policy initiatives of states to which the western wind would be delivered


For example, if states in the east coast have public policies support off- shore wind, what is the need for long-distance transmission to deliver wind from the Great Plains?


Looking at the system as a whole, need to consider difficulties in transmission siting, i.e., nearby is better, takes less time, less siting issues 

For the aforementioned reasons, I sincerely support and endorse Wind Catcher Energy Connection and the benefits that it will bring to Oklahoma. Oklahoma cannot afford to miss out on this opportunity to invest in our state and the citizens of Oklahoma. I would like to thank the Oklahoma Corporation Commission for their thoughtful consideration on this matter.

The CAD takes no prisoners in its attempt to “advise” the Commission of its responsibilities. In its Reply Brief, the CAD emphasizes the gravity of the situation by stating that, if this Transaction is approved, “the harm that redounds to West Virginia captive ratepayers will be a legacy of this Commission.”

Additionally,the Companies will not accept the conditions included in the Commission Order that would result in Mon Power assuming exposure and significant commodity risk, which is inconsistent with FirstEnergy’s announced corporate strategy.

First, the rate benefit to residential ratepayers is a one year benefit of $11.52. The Companies provided no evidence of rate impacts beyond December 2018. The absence of this information is intentional.

As originally proposed by the Companies, if the acquisition of Pleasants is approved, there will be a $31,486,971 net decrease in rates for the 16-month period of September 1, 2017 through December 31, 2018, which is a 1.6% overall decrease. Residential customers would experience a decrease of about 0.9%. The decrease for a residential customer using 1,000 kilowatt-hours per month would be $0.96 per month, which would result in a decrease to $111.52 from 112.48 per month.  It is important to note that the decrease in customer rates is guaranteed only through December 2018.

West Virginia captive ratepayers are not hedge managers or virtual traders in the PJM markets. If the Commission approves this transaction that is what they will become: buyers of significant surplus capacity that Companies are betting (on their behalf) will provide benefits for years into the future. Pleasants was rejected by FirstEnergy as too risky. The overwhelming evidence in this case contradicts all Companies’ claims that there will be any benefits to captive ratepayers. Now FirstEnergy wants Companies to manage that risk for 500,000 ratepayers. As the legal representative of ratepayers, no thank you. The Pleasants acquisition should not be approved.

The CAD must begin by emphasizing that if this transaction is approved the harm that redounds to West Virginia captive ratepayers will be a legacy of this Commission.

The already-strong demand for imports of low-cost wind energy into the mid-South and Southeast would likely increase if and when states in the region are subject to regulations limiting greenhouse gas emissions from power plants. EPA’s Clean Power Plan, published in October 2015 and scheduled to mandate compliance beginning in 2022, aims to “continue progress already underway in the U.S. to reduce CO2 emissions from the utility power sector” and is part of a suite of air quality improvements sought by other national environmental regulations. These improvements could be accomplished through retrofitting of older generation plants, plant retirements, and an increasing reliance on local or imported low-carbon generation including renewables. The Department’s Energy Information Administration (EIA) estimates that the Clean Power Plan would result in strong growth in renewable generation, particularly in regions currently lacking robust renewable portfolio standards such as the Southeast. Implementation of the Clean Power Plan would also shift the regional fuel mix away from baseload capacity with on-site fuel supplies (such as coal, nuclear, hydroelectricity, and oil) towards capacity that tends to utilize real-time fuel delivery (wind, solar, and natural gas).  Overall, wind generation is projected to play a major role and become increasingly economically competitive. Although the EIA’s analysis did not look at the degree to which such a fuel mix would be imported to the Southeast or conduct a detailed model of the transmission system, it did find that “[c]ompliance with the proposed rule could necessitate significant investment in electric transmission system infrastructure to integrate renewables from remote areas.”

To be sure, wind power delivered by the Project will compete with other sources of renewable energy in markets in the mid-South and Southeast. But such competition is healthy, and ultimately benefits consumers and the renewable energy sector as a whole. Indeed, new transmission links such as the Project create value through their ability to foster healthy competition among generators. As the Commission has observed: “New interconnections and transmission service generally meet the public interest by increasing power supply options and improving competition.” The Commission has also explained that “as a general matter, the availability of transmission service enhances competition in power markets by increasing power supply options of buyers and sales options of sellers, [resulting in] lower costs to consumers.”

Each Commission-approved independent system operator or regional transmission organization shall establish a tariff that provides a just and reasonable rate for the (A) purchase of electric energy from an eligible reliability and resiliency resource and (B) recovery of costs and a return on equity for such resource dispatched during grid operations. The just and reasonable rate shall include pricing to ensure that each eligible resource is fully compensated for the benefits and services it provides to grid operations, including reliability, resiliency, and on-site fuel assurance, and that each eligible resource recovers its fully allocated costs and a fair return on equity.

Our Mission

The Edison Electric Institute (EEI) is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for 220 million Americans, and operate in all 50 states and the District of Columbia. As a whole, the electric power industry supports more than 7 million jobs in communities across the United States. In addition to our U.S. members, EEI has more than 60 international electric companies as International Members, and hundreds of industry suppliers and related organizations as Associate Members.
 
Organized in 1933, EEI provides public policy leadership, strategic business intelligence, and essential conferences and forums.

Our Vision
EEI will be the best trade association.

We will be the best because we are committed to knowing our members and their needs. We will provide leadership and deliver services that consistently meet or exceed their expectations.

We will be the best because we will attract and retain employees who have the ambition to serve and will empower them to work effectively as individuals and in teams.

Above all, we will be the best trade association because, in the tradition of Thomas Edison, we will make a significant and positive contribution to the long-term success of the electric power industry in its vital mission to provide electricity to foster economic progress and improve the quality of life.

When third-party organizations or public service commission staffs have attempted to protect ratepayers from funding political organizations in recent years, their attempts have met with fierce resistance from the utility companies.

This report explores how regulated utility companies are including their Edison Electric Institute (EEI) annual payments, along with payments to other trade associations, in their operating expenses. The widespread practice forces ratepayers to pay for political and public relations activities with which they may not agree, and from which they do not benefit. It also has the effect of ratepayers subsidizing the political activities of EEI and other trade associations. Utility commissions have a responsibility to protect ratepayers from paying for industry groups and their political work along with public relations activities. But utilities have become adroit at using EEI, and other organizations, to effectively and quietly influence policy while sheltering their shareholders from the bulk of the associated costs. Almost no other political organizations have the luxury of subsidization enjoyed by EEI and other representatives of the regulated utility industry.

The evidence in this report reveals that EEI is primarily and inherently a political organization, and that much of its work targets policymakers throughout all levels of government to build influence, specifically for their member companies but also for the industry at large. While many states have their established practices of how to code trade association dues, they should revisit outdated guidelines due to the nature of EEI’s modern activities to ensure that they are adequately protecting ratepayers. Throughout the past three decades, some regulators and consumer advocates have acted to protect ratepayers, but scrutiny has waned dramatically. Precedent exists for public officials to act in every state to investigate whether or not EEI’s inherently political work ought to be funded by ratepayers.

For years the citizens of Maryland have been waiting to find out whether the Public Service Commission really cares about justice and protecting the public. We have our answer. The answer is NO!

The Maryland Public Service Commission (PSC) in their recent Order has taken a position in support of Potomac Edison (PE) on the major issue, against ratepayers’ interests. The Commissioners’ decision is in conflict with both their own Judge’s determination and the West Virginia Public Service Commissioners on the same issue.

The most important decision on this matter was whether or not to require PE to read meters monthly. The PSC Commissioners, as usual, supported the utility company when they overturned the Order issued by the Judge who heard the case.

This should have been expected because in every meeting and mediation, PE’s attorney would declare that PE will not do monthly reads! Apparently lawyers and attorneys trump justice every time! We now know our PSC stands for money in politicians’ and big businesses’ pockets without concern for the problems and concerns of the people or justice at all.

As a brief history, in May 2012, as President of Sugarloaf Conservancy (Doug) filed a formal complaint with the PSC asking them to “establish a formal case to investigate this matter” in response to members’ complaints about PE meter reading practices.  These practices included the failure of the company to read meters bimonthly as required, using inaccurate estimations, which caused substantial over and under billings. Both situations have negative ramifications causing harm to those who can least afford to pay overcharges or large catch-up bills.

A case was finally opened in April 2013. After years of delay the Judge in May 2016 ruled against PE. In part of his Order he stated, “I find that PE's meter reading tariff must be modified to require an actual reading on a monthly schedule...” (as is the case with all other electric utilities in Maryland).  PE appealed the Judge’s Order. A year passed without any decision by the Commissioners. On May 16th, in a letter sent to the PSC, we insisted they fulfill their obligation. Finally on June 19th, the PSC issued an Order.

The Order upholds most of the findings of the Judge’s ruling, including that PE must submit a monthly report for 24 months; pay a minor penalty of $25,000; offer a payment plan to those customers who receive a substantially low estimate bill, followed by a substantial catch up bill the following month; modify their bill to clearly show when an estimate occurs and the reason for not reading the meter.  The reversal of the Judge’s Order to require PE to read meters monthly is in stark contrast to a similar case in West Virginia. West Virginia took less than a month to open a case after the issue was raised whereas the Maryland PSC waited a year after we asked for an investigation; Maryland dragged out the case for four years before the Commissioners issued a final Order; West Virginia issued a comprehensive ruling against PE including the requirement that they read meters on a monthly basis after only a year.  Maryland PSC Order required PE address only 4 areas of concern whereas in West Virginia their PSC hit PE on twelve major requirements.

There is great concern that this slap on the wrist will embolden PE to resume their past business practices, which have caused severe harm to so many.  Unfortunately the losers will be the senior citizens on a fixed income and the poor who can least afford to either pay for electricity they have not consumed or be hit with a sizable catch-up bill.  The Commissioners, through this Order, confirmed their past history of supporting utility companies at the expense of ratepayers in Maryland. This pattern should be disturbing to everyone and unfortunately will not likely change.