Pepco has been taking a lesson from the way PATH is getting kicked around at FERC. After watching PATH run willy-nilly into the abandonment pool without any little arm floaties, or even a bathing suit, at the end of September, Pepco filed with FERC to collect $87.5M in stranded investment for its MAPP (Mid-Atlantic Power Pathway) Project on December 21.
Pepco says they had $101M sunk into the project, but have "mitigated" the damage to consumers by transferring some materials and overhead to other projects and putting the $11M Burches Hill substation upgrades (that will now never be used) into service. Pepco is asking for $87.5M, to be further "mitigated" by transferring or selling other project assets in the future.
Rights-of-way acquired by Pepco will simply be transferred elsewhere to be held for future use. If you were unfortunate enough to have signed an agreement with MAPP/Pepco to allow the company a right-of-way on your property, rest assured that the company will be sure to put a transmission line on your property at some time in the future. You're not off the hook, like the majority of the landowners who caved in to pressure from PATH land agents.
While PATH voluntarily gave up its 150 basis point incentive ROE adder when it filed for abandonment, and had the remaining 50 bpa for membership in PJM wrested away from it by the Commission, Pepco thinks the Commission should award it the full 12.8% incentive ROE it was originally awarded. Seriously, Pepco? Got into the holiday spirits a little early this year? Here's Pepco's silly justification for continuing to collect a 12.8% return over its proposed 5-year amortization period:
"The PHI Companies are aware of the recent order in PJM Interconnection, LLC and Potomac-Appalachian Transmission Highline, L.L.C., 141 FERC ¶ 61,177, P 71 (2012) (“PATH Abandonment Order”), in which the Commission found that the 50 basis point RTO participation adder should not continue because the applicants in that case would not be taking steps to turn over operational control of their facilities to PJM and would have no future physical facilities. The Commission’s finding in this regard should not apply to the instant filing for several reasons. First, in contrast to PATH, which is a stand-alone entity that will cease operations after its recovery period, the PHI Companies have turned over operational control of all their transmission facilities to PJM (including the Burches Hill substation and related facilities constructed during the development of the MAPP Project). Moreover, as stated above, the Commission already has approved the ROE applicable to the MAPP Project (150 basis points above the PHI Companies baseline approved equity return and the 50 basis point adder for RTO participation). Although the Commission’s statement in the PATH Abandonment Order, 141 FERC ¶ 61,177, at P 71, indicates that ROE adders are not appropriate in abandonment filings, such direction must be construed as applying prospectively only. That is, if the determination in PATH is now the Commission’s policy for RTO participation adders, it must apply only to transmission incentive orders issued after the date of the PATH Abandonment Order."
*hiccup* *WAHHHH!*
Pepco also includes some very detailed cost breakdowns of the investment they are now proposing to collect. In contrast, PATH provided NO cost data. PATH was in a real big hurry to make their abandonment filing and consolidate it with the Challenges, after the Commission set the $6M Formal Challenges for hearing on September 20. PATH was in such a hurry, it filed no cost data at all. That seems to have worked out really swell for PATH so far, hasn't it?
So, the abandoned PATH project is proposed to cost consumers $250M, and now the MAPP project isn't far behind. Cost of PJM's failed Project Mountaineer initiative to electric consumers in 13 states, plus the District of Columbia, could approach a half billion dollars, while absolutely NO benefit was received for this outrageous consumer expenditure.
Consumers can't afford the PJM cartel's poor planning any longer.
Pepco says they had $101M sunk into the project, but have "mitigated" the damage to consumers by transferring some materials and overhead to other projects and putting the $11M Burches Hill substation upgrades (that will now never be used) into service. Pepco is asking for $87.5M, to be further "mitigated" by transferring or selling other project assets in the future.
Rights-of-way acquired by Pepco will simply be transferred elsewhere to be held for future use. If you were unfortunate enough to have signed an agreement with MAPP/Pepco to allow the company a right-of-way on your property, rest assured that the company will be sure to put a transmission line on your property at some time in the future. You're not off the hook, like the majority of the landowners who caved in to pressure from PATH land agents.
While PATH voluntarily gave up its 150 basis point incentive ROE adder when it filed for abandonment, and had the remaining 50 bpa for membership in PJM wrested away from it by the Commission, Pepco thinks the Commission should award it the full 12.8% incentive ROE it was originally awarded. Seriously, Pepco? Got into the holiday spirits a little early this year? Here's Pepco's silly justification for continuing to collect a 12.8% return over its proposed 5-year amortization period:
"The PHI Companies are aware of the recent order in PJM Interconnection, LLC and Potomac-Appalachian Transmission Highline, L.L.C., 141 FERC ¶ 61,177, P 71 (2012) (“PATH Abandonment Order”), in which the Commission found that the 50 basis point RTO participation adder should not continue because the applicants in that case would not be taking steps to turn over operational control of their facilities to PJM and would have no future physical facilities. The Commission’s finding in this regard should not apply to the instant filing for several reasons. First, in contrast to PATH, which is a stand-alone entity that will cease operations after its recovery period, the PHI Companies have turned over operational control of all their transmission facilities to PJM (including the Burches Hill substation and related facilities constructed during the development of the MAPP Project). Moreover, as stated above, the Commission already has approved the ROE applicable to the MAPP Project (150 basis points above the PHI Companies baseline approved equity return and the 50 basis point adder for RTO participation). Although the Commission’s statement in the PATH Abandonment Order, 141 FERC ¶ 61,177, at P 71, indicates that ROE adders are not appropriate in abandonment filings, such direction must be construed as applying prospectively only. That is, if the determination in PATH is now the Commission’s policy for RTO participation adders, it must apply only to transmission incentive orders issued after the date of the PATH Abandonment Order."
*hiccup* *WAHHHH!*
Pepco also includes some very detailed cost breakdowns of the investment they are now proposing to collect. In contrast, PATH provided NO cost data. PATH was in a real big hurry to make their abandonment filing and consolidate it with the Challenges, after the Commission set the $6M Formal Challenges for hearing on September 20. PATH was in such a hurry, it filed no cost data at all. That seems to have worked out really swell for PATH so far, hasn't it?
So, the abandoned PATH project is proposed to cost consumers $250M, and now the MAPP project isn't far behind. Cost of PJM's failed Project Mountaineer initiative to electric consumers in 13 states, plus the District of Columbia, could approach a half billion dollars, while absolutely NO benefit was received for this outrageous consumer expenditure.
Consumers can't afford the PJM cartel's poor planning any longer.
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