Here's your quick reference guide to the resources available at StopPATH WV to assist you in crafting your comments on FERC's Notice of Inquiry Promoting Transmission Investment Through Pricing Reform. Hopefully this contains everything you need to know, but if you have additional questions, email me. You can also leave comments in the individual blog entries, but there's no guarantee I will see them in a timely fashion.
Extended comment deadline - August 25, 2011
How to submit your comments
General Overview of NOI
Overarching Questions pp. 1-10
Sec. 219(a) Statutory Threshold (Rebuttable Presumption) pp. 10-12
Additional Goals in Sec. 219 pp. 12-14
The Nexus Test pp. 14-19
Interrelationship of Incentives pp. 19-20
The Role of Cost Estimates pp. 20-21
Incentive ROE Adders pp. 23-27
Abandonment pp. 27-30
CWIP in Rate Base pp. 30-33
Hypothetical Capital Structure pp. 33-34
Pre-Commercial Cost Recovery p. 34-36
Accelerated Depreciation and Advanced Technology pp. 36-40
We encourage both groups and individuals to submit comments. For individuals, it might be easier to concentrate on just one aspect of the NOI. Detailed comments on a particular incentive or aspect are better than generalized comments on the entire NOI. We are encouraging groups to combine resources and file a comprehensive set of comments.
FERC's Transmission Incentives are the "root of all evil" and the impetus for all the unneeded transmission projects that we've been plagued with. These projects have cost consumers and landowners hundreds of thousands of dollars in defensive legal costs, years of stress and aggravation, and in some unfortunate cases caused complete financial ruin. If you want to put a stop to this nonsense once and for all, don't miss this fortuitous opportunity to have a voice.
Extended comment deadline - August 25, 2011
How to submit your comments
General Overview of NOI
Overarching Questions pp. 1-10
Sec. 219(a) Statutory Threshold (Rebuttable Presumption) pp. 10-12
Additional Goals in Sec. 219 pp. 12-14
The Nexus Test pp. 14-19
Interrelationship of Incentives pp. 19-20
The Role of Cost Estimates pp. 20-21
Incentive ROE Adders pp. 23-27
Abandonment pp. 27-30
CWIP in Rate Base pp. 30-33
Hypothetical Capital Structure pp. 33-34
Pre-Commercial Cost Recovery p. 34-36
Accelerated Depreciation and Advanced Technology pp. 36-40
We encourage both groups and individuals to submit comments. For individuals, it might be easier to concentrate on just one aspect of the NOI. Detailed comments on a particular incentive or aspect are better than generalized comments on the entire NOI. We are encouraging groups to combine resources and file a comprehensive set of comments.
FERC's Transmission Incentives are the "root of all evil" and the impetus for all the unneeded transmission projects that we've been plagued with. These projects have cost consumers and landowners hundreds of thousands of dollars in defensive legal costs, years of stress and aggravation, and in some unfortunate cases caused complete financial ruin. If you want to put a stop to this nonsense once and for all, don't miss this fortuitous opportunity to have a voice.
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