Blog Posts

Potomac Edison Meter Reader Imposters?

8/19/2013

Here's why contract meter readers without uniforms or company vehicles are a bad idea:

Imposter

Imposter

Imposter

Imposter
(this one is especially fun because the imposter offered to alter the electric meter to reduce the customer's bill)

Imposter

So, how do you know when a meter reader is the real thing?

This story says a real meter reader will be sporting a:

Shirt and vest with company logo
ID badge

And they come once a month.

Or maybe imposters just work for FirstEnergy, who is too cheap to buy uniforms or company vehicles for its meter readers. In fact, FirstEnergy is too cheap to even hire enough meter readers to come as required every other month.

For this, you each pay $5.00 per month.

A Visit From the Potomac Edison Meter Reader As Told By My Dog

8/15/2013

"Woof, woof," said Ms. Lindy.

"An intruder has been spotted in the driveway! He looks like this..."

But when I looked outside, it was just an

wearing a

and driving a pick up truck that had orange and blue stripes, like this, but also a confusing logo that said "Potomac Edison"

To add to our confusion he wasn't wearing a

So we couldn't be sure whether he really was a Potomac Edison meter reader or a ninja burglar.

What do you think?

Here We Go Again -- FirstEnergy's Plant Closure Game Costly to Consumers and Unfair to Workers

8/14/2013

Wow, what a shocker! FirstEnergy's grid monkey, PJM Interconnection, has determined that the two coal-fired power plants the company recently announced for closure in October are necessary for reliability. In order to keep the plants open until FirstEnergy can further add to its corporate coffers by making transmission upgrades to take the place of these two generators, PJM will offer the company what's known as reliability must run (RMR) contracts. RMR contracts provide a big pay day for FirstEnergy in exchange for extending the closing date of Hatfield's Ferry and Mitchell and keeping the plants available to ensure reliability. And, like every other dime PJM spends, the money for the RMR contracts is added to your electric bill. How long will this last, how much will it cost consumers, and how much will FirstEnergy profit from its plant closure game? Nobody knows.

PJM is an industry-run cartel. How else can companies like FirstEnergy continue to play the same game over and over and get away with it? According to PJM's rules, a generator must only give 90 days notice that it will close. Can PJM build a replacement generator or make necessary transmission upgrades in 90 days? Of course not. Did this rule ever make any sense, or was it specifically set up to be gamed in this fashion and produce unearned profit for PJM utilities? The only way you can prevent being gamed this way is to build your own generator by installing solar or another renewable resource on your home or business.

FirstEnergy's decision to close these plants, followed by a subsequent decision to keep them open indefinitely isn't fair to its workers either. Closing the plants on short notice without providing a transition plan for the employees is bad enough, but now FirstEnergy prolongs their agony by dragging it out. Maybe the company should use this reprieve to help their employees find or train for new jobs, but they won't. FirstEnergy simply doesn't care. Will FirstEnergy share its RMR windfall with these displaced workers to ease their transition to new jobs? Of course not, that extra money goes in Tony's pocket! Workers are expendable to companies like FirstEnergy.

The only thing missing from this round of the FirstEnergy Plant Closure game so far is an artificial generation shortage that drives up capacity prices in the region. Shall we expect that to happen at the next auction?

How does this keep happening? PJM and its silly rules and "markets" don't save you any money.

PJM's 2013 Stakeholder Survey

8/13/2013

The PJM cartel likes to pat the stray consumer who ventures into its lair on the head and pretend that they are "stakeholders" who matter. Go ahead, pull up a chair, little consumer, our cartel is transparently open to all... except when its not.

The PJM cartel is a private club meant for the MWM (Members Who Matter - thanks, Bill!). The rest of you "stakeholders" only have a role in ensuring that PJM's annual budget of $32M is adequately funded. Other than that, PJM really doesn't care what you think.

Now, imagine the shock and horror of one bourgeois "stakeholder" who received the following email invitation to participate in PJM's Stakeholder Survey yesterday.

PJM aims to provide you and your organization with the best possible service. To achieve that goal, PJM surveys the organizations with which they work to ask you what they are doing right and – more importantly – what could be done better. The survey is very important and takes approximately 20-30 minutes.

To take the confidential survey, click on the link below:
https://www.metrus2.com/snapwebhost/surveylogin.asp?k=*REDACTED*

If the link does not work please copy and paste it into the address bar in your browser, or simply go to the websitewww.metrus2.com/pjmstakeholder and enter your survey access code: *REDACTED*. You can also go to http://www.pjm.com/about-pjm/who-we-are/stakeholder-satisfaction-survey.aspx

Metrus Group is the survey research firm selected to administer the survey. Metrus Group will not ask for or collect any personal information. Your responses will be completely confidential. The survey access code lets Metrus Group know which stakeholder organization you are from.

Thanks in advance for your help. Your responses will enable PJM to maintain the high service levels you deserve and they desire. If you have questions or need assistance you may contact the PJM Hotline at (866)-400-8980, or Metrus Group via email [email protected] or (908) 231-1900 and ask for the PJM support team.

Sincerely,

Jerry Seibert
Vice President
Metrus Group

The funny part here is that the recipient of this email hasn't paid PJM one whit of attention for several years, has no clue what "organization" he is supposed to be representing, or how PJM even got his name and email address. That's right, PJM, you managed to send your survey invitation to a common ratepayer!

They weren't lying about this survey taking 20 - 30 minutes. It's quite extensive and if you've used any of PJM's "services" over the past year, it can expand endlessly like a window, inside a window, inside a window, ad finem. But, it's the best look us plebeians are going to get at what the cartel club considers important. Like royalty everywhere, PJM just doesn't realize how arrogant they come across. Here are a select few survey questions:

PJM wants to know about its "corporate reputation" and how you would rate them on the following:

Being well-managed, trustworthy, innovative, an industry leader, attracting and retaining the best and brightest employees, having efficient processes, having required systems and infrastructure in place AND the most important:

Helping my company succeed and being easy to do business with, because the PJM cartel's first mission is to help its members make money! What? You thought PJM's mission was to keep the lights on? Ha ha ha, you little prole, what a kidder!

PJM also wants to know how well they've done educating stakeholders and helping members work toward consensus of stakeholder issues.

PJM also wants your opinion on their food and "making you feel valued." What is this, a Chuck E. Cheese franchise, or a regional grid operator? Who knew PJM was a vacation destination?

PJM also wants to know where you get your information about them (because propaganda is only useful if it is disseminated correctly):
Inside Lines, committee emails, communication with PJM employees (ultra-secret meetings where unneeded transmission projects are propped up endlessly), communication with committee members, trade media, pjm.com, or a company representative.

PJM asks: Have you read, seen or heard anything in the news media about PJM in the last six months? (In other words, are you Amish?)

What sources do you find useful for providing industry info.? (because PJM needs to make sure their propaganda reaches these markets):

Internet search engines such as Google or Bing, Industry-specific blogs, Internet news sites such as CNN.com, Blogs and/or online discussion groups, Twitter, Facebook, RSS feeds, YouTube or trade media, newsletters or news media. For any you checked, be sure to now check them off your list of reliable sources in the future.

Perhaps PJM doesn't have the right kind of role model in Mother FERC, but the purpose of an RTO is supposed to be to ensure open access and non-discriminatory transmission services, the continued reliability of the system, and to operate wholesale electricity markets that provide electricity suppliers with more options for meeting consumer needs for power at the lowest possible cost.

It's really not all about providing a smokescreen for investor owned utility transmission building schemes, wining and dining utility executives, or helping investor owned utilities to succeed. It's supposed to be about serving the electric consumer, or "stakeholder."

Here's how PJM might go about doing a real "stakeholder" survey: The following question, and a mechanism for every one of PJM's 60 million "stakeholders" to individually answer it, should be featured on every cable news channel and on the front page of USA Today:

Have you ever heard of PJM Interconnection and how it serves consumers?

Transmission Assets are a Goldmine, Says Bankster

8/12/2013

Transmission's biggest cheerleaders met last month in San Diego to talk about a subject near and dear to their wallets. During his presentation to his fellow speculators, Ray Wood, head of U.S. power and renewables at Bank of America Merrill Lynch said:

“Transmission assets, when they're already built, are goldmines,” he said. “They've got a long life, they're stable, and generally not as subject to tariff reductions as other asset classes because the percentage of the bill that ultimately goes to the end user that revolves around transmission is relatively light.”

Wood wasn't just bragging, however, but trying to convince everyone that transmission needs big, double-digit rates of return in order to attract capital.

According to Wood, funds for transmission are readily available, however transmission is so risky that no one wants to invest in it until a project has been awarded a "notice to proceed."

This is a lie. There is no risk involved in building transmission. Transmission incentives awarded by FERC routinely place all risk on consumers. One incentive awarded by FERC to all who ask is guaranteed recovery of 100% of prudently-incurred project cost. Another is the ability to collect a return on investment during the construction period (CWIP in rate base). The investor cannot lose if he is guaranteed to receive his entire investment back, plus a generous return, even before the project is constructed.

What Wood is whining about is that brief period of time between the day some transmission owner rolls out of bed with the idea to build a transmission goldmine, and the day incentives and a formula rate are approved by FERC. This is the only time when investment isn't earning a great big return. After that, it's all $$$$$!

Wood pretends that there's some further risk during other necessary approvals, such as a state CPCN or an environmental review. The investor is still earning during this time -- where's the risk? The only "risk" is that a project may be abandoned if it cannot buy necessary approvals, therefore the "sky's the limit" amount of investment that it was possible to make actually constructing the project is curtailed, and the investor is left with a smaller investment that is still earning around 12%. Oh, boo hoo.

And what about projects sponsored by transco spinoffs of gigantic investor owned utilities? These companies often self-finance the early cost of a project by borrowing at the parent company level at extremely low rates, and then earning a 14.3% return on that investment. In the case of the PATH project, the company never borrowed any money, however they still collected a 14.3 or 12.4 percent return on money they probably borrowed at 3 or 4%.

So, how do we fix this to make both Wood and electric consumers happy? How about setting limits on incentive rate of return periods to coincide with the "risky" periods of a transmission project? Transmission is only competing with other investments at the beginning. Once the investment is made and the project constructed, all risk disappears. So, what if incentive ROEs were gradually lowered over the life of the asset? As well, incentive ROEs should not kick in until an actual investment in the project has been made by an entity other than the company or its parent. Transmission owners are scamming us big time!

FirstEnergy: Too Many Chiefs and Not Enough Indians

8/11/2013

Check out the list of Potomac Edison and Mon Power staff over the last 4 years that was filed in the PSC General Investigation on Friday.

It's pretty obvious that the number of Meter Readers has fallen since the FirstEnergy/Allegheny Energy merger.

Oops, FE.

But check out the bloated number of managers, directors, and "senior" personnel, which seems to be on the rise.

Who do you think is going to keep the lights on here? Not these "managers." If FirstEnergy was a bee colony, this hive full of queens and drones would starve to death.

Powering America for Tomorrow Act, HR 2762 -- Will the Third Time be the Charm?

8/11/2013

The piggish Rep. James Sensenbrenner (R-WI) has once again resurrected his twice-trounced "Powering America for Tomorrow Act." We caught this piece of scary legislation the last time he introduced it. It hasn't gotten any better this time around.

This legislation would establish regional transmission planners that would take over CPCN permitting and siting for interstate transmission projects.

‘‘(d) CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY.--
‘‘(1) PROPOSED FINDING OF PUBLIC CONVENIENCE AND NECESSITY BY REGIONAL TRANSMISSION PLANNER.--
‘‘(A) INCLUSION OF PROPOSED FINDING IN REGIONAL TRANSMISSION PLAN.—As part of a regional transmission plan submitted to the Commission under subsection (c)(3), a regional transmission planner may identify a regional transmission project or projects that such regional transmission planner finds, based on the record of the regional transmission planning process, is required by, and consistent with, the public convenience and necessity.
‘‘(B) PUBLIC CONVENIENCE AND NECESSITY CERTIFICATE REQUEST.—A regional transmission planner may submit to the Commission a request to issue a certificate of public convenience and necessity for a regional transmission project identified in a regional transmission plan submitted under subsection (c)(3). Such request shall include a summary of the record developed for such project during the regional transmission planning process. The request shall be based on whether such regional transmission project is or will be--
‘‘(i) necessary to ensure regional compliance with reliability standards or remedy violations of such reliability standards;
‘‘(ii) necessary to provide significant relief from electric transmission congestion as measured by objective criteria, including consideration of the total cost of congestion, hours of congestion, and the lack of feasible economic alternative means to relieve congestion;
‘‘(iii) important to the diversification of energy supply throughout the designated region, including by meeting the goals of applicable renewable portfolio standards; or
‘‘(iv) important to the development of smart grid technology that is consistent with the policy under title XIII of the En-
ergy Independence and Security Act of
2007 (42 U.S.C. 17381 et seq.).
‘‘(2) ISSUANCE OF CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY.—The Commission may, after notice and opportunity for hearing, find that a regional transmission project is in the public convenience and necessity and issue a certificate of public convenience and necessity for the ownership and operation of such regional transmission project and the provision of any related services under the jurisdiction of the Commission if the Commission
finds that—
‘‘(A) a regional transmission planner included a proposed finding of public convenience and necessity for such proposed regional trans- mission project in one or more relevant regional transmission plans submitted to the Commission under subsection (c)(3);
‘‘(B) a regional transmission planner submitted a request for the issuance of such a certificate;
‘‘(C) the proposed regional transmission project will be used for the transmission of electric energy in interstate commerce;
‘‘(D) the proposed regional transmission
project is consistent with the public interest in terms of its engineering, reliability, and other economic characteristics and the purposes of this section; and
‘‘(E) the proposed regional transmission project will maximize, to the extent reasonable and economical, existing rights-of-way and the transmission capabilities of existing towers and structures.
‘‘(3) CONSIDERATIONS.—In issuing a certificate of public convenience and necessity under this subsection, the Commission shall give substantial deference to any proposed finding of public convenience and necessity by a regional transmission planner in a regional transmission plan submitted under subsection (c)(3).

Oh, and environmental reviews? We throw those out the window:

‘‘(6) ENVIRONMENTAL REVIEW.— ‘‘(A) PROPOSED FINDING BY REGIONAL
TRANSMISSION PLANNER.—A proposed finding by a regional transmission planner of public convenience and necessity regarding a regional transmission project is excluded from review under the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.), provided an environmental assessment or environmental impact statement is required to be prepared by the Commission under such Act.

I think Sensenbrenner got a hold of a bad batch of cheese curds, like maybe some from ALEC Farms. Lest you think he's nothing but a mindless corporate flunkie though, Porky gave a speech at a recent WIRES lobbyist meeting that would have removed any doubt.

Just like when the little pig cried wolf (oh, am I mixing my fables again?) we probably shouldn't pay any attention to this. Govtrack gives this bill a 2% chance of getting out of committee, but stranger things have happened. Keep an eye on this piece of pork.

Knock, Knock, Is it a Potomac Edison Meter Reader or a Criminal?

8/9/2013

FirstEnergy's continued cuts to operating expenses (more were announced just the other day) have now opened the door for scammers to take advantage of the company's customers.

Read this report by Potomac Edison Customer Danny Lutz:

At about 0840 hours this morning, I observed a white SUV with a Virginia Vanity plate OHAPY DZ in my front yard. The vehicle had a portable orange flashing light affixed to the right front rain gutter.
       Upon checking, the individual, clad in a black pullover shirt, and black knee top Speedo type shorts, waived an electronic device at me. He stated he was from the power company and was there to read the meters. (This is the "uniform" of street thugs, burglars, muggers, MS 13.... keep picking them.)
       The gentleman showed nothing to confirm his position with Potomac Edison, nor did he identify himself.
        I allowed him to complete his errand. Then I asked him if Potomac Edison is requiring meter readers to use their personal vehicles when making their rounds.
        He stated that "Since the merger, everything is all screwed up, and I have to use my vehicle."
        Imagine the scams that could be perpetrated upon the unknowing of all ages by people posing as meter readers. I do not know if my premises were cased for a later visit for less than legal purposes.
        I very much should like to know what explanation Potomac Edison has for this modus operandi. Could not Potomac Edison hire someone from West Virginia to read West Virginia meters?
        I politely suggest that in addition to being more vigilant over your own properties, you should watch for and warn your neighbors, especially those living alone, elderly, or incapacitated.

Danny later reports:

After an interminable number of attempts, I finally breached FORTRESS FIRST ENERGY and reached TODD MEYERS, in house apologist.
       I gave him the same description of the events of 0840 hours yesterday morning.
       He offered the explanation that some meter reading personnel hired since 1 April 2013 may not have Potomac Edison Vehicles.
       Meyers stated that those using personal vehicles "should" have a magnetic door sign identifying the vehicle as representing Potomac Edison. (This vehicle had no such signage.) He further asked if any ID BADGE was displayed. (None was) Meyers stated that the reader should have been wearing a lime green safety vest.(He was not.)
       He kept repeating "You've given me good enough information. I can investigate this. I will call the meter reader and find out what is going on."
      It took me eight calls plus a boat load of web searches to finally get to Meyers.
      The last two individuals who came here to read the meter, months ago, drove pick ups and wore white helmets and lime green safety vests.
    I will be curious to see what comes from this belated effort.
       If Potomac Edison would use local people from the areas to be served, some of these issues might need never arise. Though local people cannot know everyone, they are able to be more easily identified.

And finally, Danny got tired of waiting for a reply from Meyers:

    Just had an enlightening conversation with Todd Meyers "Public Relations Specialist with FIRST ENERGY." (That is how Mr. Meyers described his capacity with FIRST ENERGY in our conversation a few minutes ago.)
        I was able to contact the gentleman on the first call, and he doubtless saw who I am from the caller ID. He clearly did not want to talk to me.
        I had to give him another synopsis of the issues of 7 August 2013.
        In a stumbling, hesitating voice, Mr. Meyer stated that he had checked with the Supervisor of the meter reading and found that, indeed, the vehicle and the person are engaged in reading meters for Potomac Edison. He stated that this was determined by conversing with that supervisor from "the information which you supplied, that is the white vehicle with the O HAPPY DAYS (sic) Virginia plate." (Actual plate is OHAPY DZ.).
        Meyers further stated that he had learned that the individual in question had displayed an ID, was wearing a green vest, and had magnetic signs on the door of the vehicle.
        I asked who was the source of his information, and he was reluctant to tell me, giving a rambling and convoluted answer which I shall not try to duplicate here.
       Meyers went on "That's what I was told happened."
       I asked "Might I ask who is the supervisor of the meter reading for this area?"
       Meyers replied "That is Charity Emmert in the Williamsport office."
       I said "Could you provide me with an email for you and Ms. Emmert that I may inform you, Ms. Emmert, and Potomac Edison that that person is not welcome on my property again for any reason? It appears that person has been less than truthful in this matter."
       MEYERS "You can send the email to me at tmeyer1energy.com, I will see that she gets it. I will forward it to where it needs to go,"
       I suspect that TOADIE MEYERS did not do anything with my complaint, and was surprised to have his bluff called in this manner.

Nice going, Todd! The fake email address adds just the right touch to your bumbling attempts to satisfy this customer.

Why aren't Potomac Edison's meter readers wearing uniforms and driving company trucks? Because those things cost money! FirstEnergy's cost cutting now allows any person to pretend to be a meter reader, even those with ulterior motives. How easy would it be to buy a lime green vest, a blinking light and a fake magnetic sign in order to go door-to-door to see who's home... or not?

Danny is not a liar. FirstEnergy needs to provide a staff of professional meter readers, not unidentified people driving anonymous vehicles and waving electronic devices. If you have a question about an unidentified person trespassing on your property that you suspect may be a Potomac Edison meter reader (or someone posing as one), do not approach. Call Todd and ask him to identify the person 724 838 6650.

FirstEnergy Fined $43 Million in Ohio

8/7/2013

Don't you just love that headline? Hopefully the first of many well-deserved slaps upside the head for this crooked company.

Yesterday, the Public Utilities Commission of Ohio (PUCO) ordered that FirstEnergy refund $43.3M to its Ohio distribution affiliates' customers within 60 days. The PUCO found that Ohio Edison Company, The Cleveland Electric Illuminating Company, and The Toledo Edison Company had grossly overpaid for renewable energy credits purchased from their own FirstEnergy Solutions affiliate and then recovered these exorbitant costs from consumers. In other words, FirstEnergy bought something from itself that was overpriced.

That's the good news. Now for the bad news.

FirstEnergy has vowed to appeal the decision. Any refunds due to customers will thus be held until the appeals process has exhausted itself. FirstEnergy intends to continue to pour millions into avoiding refunds due to struggling electric consumers, and if they are successful, consumers will end up footing the bill for the cost of that too, adding insult to injury. How long will FirstEnergy deny the consumers their refund? Maybe forever.

This whole thing smacks of a badly executed bit of play acting by PUCO and FirstEnergy executives. Everyone knows that FirstEnergy has stacked PUCO with its bought and paid for "yes" men.

This investigation has been going on for years. A decision was expected last week, but PUCO delayed it a week "to allow time to fine tune an order addressing whether the Akron-based utility overpaid for renewable energy credits and passed those excess costs on to customers." Fine tuning my eye, the decision was delayed until AFTER FirstEnergy's 2Q Earnings Call on Tuesday so that FirstEnergy's executives wouldn't have to suffer through questions about it, and so it wouldn't drag down FirstEnergy's already disappointing financial results for the quarter. So, FirstEnergy, where are you going to get the money to pay back this $43.3M that you stole from your customers? Inquiring minds want to know...

PUCO ruled that all the financial information related to its decision must be kept secret. This prevents the public from doing its own independent calculation of just how much they were ripped off. Other parties in the case contend that the theft from consumers actually amounted to more like $130M.

So, if FirstEnergy profited by selling RECs to itself in the amount of $130M, a refund of $43M is a small price to pay. FirstEnergy still comes out ahead by $87M. The company has actually been rewarded for stealing from its customers. What PUCO should really be looking into is FirstEnergy's corporate separation issues. The company is selling things to itself at outrageous prices because ratepayers are paying the bill. "Arm's length negotiation" means nothing when Tony's left arm is shaking hands with Tony's right arm, just before plunging both arms into YOUR pocket.

It's well known that PUCO is stacked with bought and paid for FirstEnergy puppets. This decision and its timing evokes imagination of the negotiations that must have occurred between FirstEnergy and PUCO to set it up to look like FirstEnergy was punished, when it was actually rewarded for stealing from the customers PUCO is sworn to protect.

Read about it here.

Meanwhile, FirstEnergy has attacked Ohio's Renewable Energy and Energy Efficiency standards as "too expensive for consumers." Maybe someone needs to look into all FirstEnergy's programs to find out why they are "too expensive." Is FirstEnergy cheating on EE recovery too?

And the bad juju continues to build...

WIRES Wants to Stop Transmission ROE Complaints Because That Cuts Into Profits

8/7/2013

WIRES, the voice of the electric transmission industry, has been as busy as a nasty, venomous, little bee trying to preserve its members’ ability to harvest buckets of ratepayer cash building new transmission of dubious necessity.

On another prong of its diabolical pitchfork, WIRES takes on the problem of recent FERC return on equity complaints alleging that transmission ROEs based on market conditions prior to the big crash are set too high. One such complaint was ruled on yesterday, when a FERC administrative law judge found that the 11.14% base ROE for New England transmission owners was unjust and unreasonable and recommended that it be reduced to 9.7%. The ALJ found that FERC’s ROE “zone of reasonableness” determined by the prior DCF analyses was inappropriate because there has been so much economic change.

With that in mind, we can approach WIRES’ petition to FERC requesting that it revamp or replace its current DCF process for setting returns, deny any future rate of return complaints under sec. 206 of the FPA as long as the ROE still falls safely within the zone of reasonableness, and that the “benefits” of a transmission project be considered as a factor worthy of a higher ROE than would ordinarily be found to be just and reasonable.

“Petitioner asks the Commission to explore methodological options that will reduce or eliminate the uncertainties and risks to investors and to customers and avoid potential reductions in investment in needed transmission facilities, higher costs, project delays, and disruption to infrastructure planning and growth.”

WIRES intends to provide electricity consumers with greater stability and predictability regarding regulated rates of return on equity (or “ROE”) for existing and future investments in high voltage electric transmission infrastructure. Well, gee, thanks, WIRES, I know that dilemma keeps everyone up at night… NOT. Are you sure you’ve really got the welfare of electricity consumers in mind? Who designated you as our representative anyhow? WIRES does NOT speak for electric consumers.

WIRES is simply stamping its gold-plated feet because the usurious ROEs it had gotten used to have come to an end. Now they want FERC to shore things up for them, and do it in a big hurry and in a way that shuts the consumers who will end up paying for it all out of the process. WIRES is frightened by all the recent section 206 complaints that are eating into transmission profit margins, and that’s because the complaints are well-founded.

Rah! Rah! Rah! Who loves transmission? Gimme a W, gimme an I, gimme an R, gimme an E, gimme an S… what does that spell? An expensive, unneeded transmission line in everyone’s back yard! Hooooooo-rayyyyyyyy!

WIRES says it’s all FERC’s fault for making the transmission biz just so gosh darn lucrative:

“…a major and substantial impetus for new investment was supplied by federal regulatory initiatives promoting regionally competitive power markets and transmission open access. It is no accident that modernization and expansion of the nation’s transmission system has coincided with implementation of the Energy Policy Act of 2005 and its directive to the Commission to provide “incentive-based rate treatments” for jurisdictional public utility transmission projects, including “a return on equity that attracts new investment in transmission facilities (including related transmission technologies).”

And therefore, it is FERC’s responsibility to continue to champion more transmission because transmission owners now depend on it as a profit center:

“Despite the continuing challenges to its planning and siting, transmission is the “critical link” between generation and customers, and its vitality is key to FERC’s bulk power market policy objectives. The industry’s principal game-changing developments of the last two decades -- open access and comparability requirements, regional wholesale power markets, accelerating network integration, the arrival of non-utility transmission investors as well as utility diversification into commercial transmission, deployment of digital monitoring and control technologies, and new forms of renewable energy -- depend significantly on the adequacy and efficiency of the grid. In recognition of that fact, transmission has emerged as a separate business and profit center, even for many incumbent transmission providers whose transmission investments were historically the by-product of service to native load.”

Well, someone has worked quite punctiliously on a strategy to dig in a foothold for transmission at a time when the composition of future energy generation and delivery is enormously uncertain, haven’t they? I don’t think this is a wise strategy for consumers, who may end up holding a gigantic bill for infrastructure that is not useful or economic. Instead of rushing headlong into $300B of new transmission intended to support more centralized generation and foster larger and costlier deregulated electricity markets, we should first be tackling the question of necessity. Even WIRES agrees with this point.

“Micro-grids, distributed generation, and energy storage technologies represent new and potentially important competition for investors’ resources.”

WIRES’ petition makes all sorts of spurious claims that all begin with a version of “once upon a time”:

“WIRES believes there is a binding norm obtained through rulemaking that would do more to ensure consistency than a policy statement. However, the need to address this particular matter within a short period of time and the familiarity of Commission staff and industry parties with the issues argue for a short comment period, followed by a Statement of Policy. Such action would shed light on the Commission’s intentions going forward while preserving its flexibility in the face of changing facts and events.”

Translation: "Let’s hurry up and get this done before someone notices!"

“Petitioner believes the investment community is, or will soon become, apprehensive about the prospect of declining transmission-related ROEs and other regulatory uncertainties.”

Translation: “Wah! You’re impeding our profits!”

“Petitioner believes that, even the most substantial increases in regulated transmission investment would rarely, if ever, result in transmission being more than one-fifth of retail rates regionally. Of course, the rate impact of regulated transmission investment on individual customers is reduced, perhaps dramatically, in relation to how broadly costs are shared. Moreover, adequate transmission enables more efficient use of generation resources; those savings will tend to offset, at least in part, any increases in transmission rates.”

Translation: “Those pesky consumers won’t notice the disgustingly high profits we’re making if we can socialize the costs broadly enough.” Again… who appointed WIRES to speak for consumers?

“Petitioner believes that the subjective judgments and evolving standards associated with application of DCF in litigated cases will significantly affect investor behavior and, if left to evolve solely through litigation, will add greater regulatory risk and uncertainty to the recognizable barriers that transmission development already faces.”

Translation: “If FERC doesn’t put a stop to ROE complaints, the investors are going to find other investments that pay higher returns, well, if they can find any that pay more than 12 – 14%, which they can’t.”

“In WIRES’ view, one key to sustaining transmission investment is rational application of the DCF methodology or such other methodologies as may appropriately fit the financial environment and Commission objectives.”

Translation: “And only high ROEs are rational, so therefore, show us the money!”

“Petitioner contends that challenges to existing or proposed rates of return need not be resolved simply on the basis of a mechanical application of the DCF model. Regulation should maintain a reasonable relationship between a project’s (or group of projects’) long-term benefits, including those that planners and regulators expect and those that flow from evolving grid operations, and the costs customers pay for securing those benefits through new transmission facilities or upgrades. Transmission benefits should therefore be part of any consideration of whether customers have been, or are likely to be, harmed by an existing allowed return.”

Translation: “We’ll make up new “benefits” for consumers if you just let us keep robbing them!”

“We are not suggesting a performance-based regulatory regime, as that is necessarily beyond the scope of the brief generic reassessment that this Petition recommends.”

Translation: “But let’s not be hasty here! Even though Congress expressly ordered that transmission incentives be subject to performance standards, FERC has failed to hold us to any standards, and that’s the way we like it!”

FERC simply cannot continue to reward failure and poor planning with unjust and unreasonable rates. If you’d like to read responses to this ridiculous and dangerous petition and/or follow this docket, you may find it here by searching for Docket No. RM13-18.

All this smoke and thunder signifies the wrath of a dying industry. Change or die, fellas, the future is here!