Although they've had four months to get it accomplished, the vast majority of the regulatory bodies, special interest groups and corporate interests waited until the last moment to submit comments on FERC's NOI Promoting Transmission Investment Through Pricing Reform. As I'm sure many of you who submitted individual comments and were added to the service list noticed, FERC was flooded with at least 50 sets (or more?) of comments yesterday. I haven't even had time to count them all, and another one just appeared from Morgan Stanley a few minutes ago. Really? A day late and a dollar short, fellas!
Due to a bunch of other issues going on, I haven't even had time to read the vast majority of them. (I'm still hoping my Acme cloning machine will arrive in the mail any day now...) If you're not on the service list and want to do some great reading (not all of them are technical, confusing minefields) here's how to find them. Go here and change the date range to "previous 1 year" and then type "RM11-26" into the Docket Number field and click "submit." That should bring up a long list of comments filed specified by author.
Some of the ones I have read that I recommend are the comments of the Virginia State Corporation Commission -- short, sweet and very much to the point.
Also recommended are comments of Transmission Access Policy Study Group. Although I disagree with their love of all things transco and their love of transmission projects in general, the law firm that wrote their comments managed to point out everything wrong with FERC's incentives policies and defended the consumers who end up paying for them. I noticed that Spiegel McDiarmid also authored some comments from other groups, but I haven't had time to read them yet to see if the theme continues.
Just about any set of comments from a state public service commission is guaranteed to be a good read, although I have only sampled a few.
On a humorous note... the comments of FirstEnergy gave me a giggle. Check out the signature block at the end. What's missing? The PATH companies! FE is backing away from their poster child that represents all that's wrong with transmission incentives. Too funny!!!
I heard that AEP made mention of PATH in a "hands off" kind of way as well. I guess the PATH parents are too proud to claim the juvenile delinquent they gave birth to.
Overall, from what little I've read, it looks like FERC is getting an earful. The comments against seem to be greater in number, but the comments from the industry are whining much louder. So, let's take a look at who's on what side of the fence:
Against Incentives - States, an couple of mystery financial analysts, some industry groups, and tons and tons of citizens who act as the Transmission Line Savings & Loan.
For Incentives - Energy and transmission corporations, some investment companies. You know, the ones who are robbing the citizen-funded Transmission Line Savings & Loan.
Could it be any more obvious? And if you think FERC still needs to have it explained to them in perfect detail, read the comments of Steven, Shirley and Samuel Smith of Charles Town. The only thing left undone was drawing them a picture.
So, what good comments have you read lately?
Due to a bunch of other issues going on, I haven't even had time to read the vast majority of them. (I'm still hoping my Acme cloning machine will arrive in the mail any day now...) If you're not on the service list and want to do some great reading (not all of them are technical, confusing minefields) here's how to find them. Go here and change the date range to "previous 1 year" and then type "RM11-26" into the Docket Number field and click "submit." That should bring up a long list of comments filed specified by author.
Some of the ones I have read that I recommend are the comments of the Virginia State Corporation Commission -- short, sweet and very much to the point.
Also recommended are comments of Transmission Access Policy Study Group. Although I disagree with their love of all things transco and their love of transmission projects in general, the law firm that wrote their comments managed to point out everything wrong with FERC's incentives policies and defended the consumers who end up paying for them. I noticed that Spiegel McDiarmid also authored some comments from other groups, but I haven't had time to read them yet to see if the theme continues.
Just about any set of comments from a state public service commission is guaranteed to be a good read, although I have only sampled a few.
On a humorous note... the comments of FirstEnergy gave me a giggle. Check out the signature block at the end. What's missing? The PATH companies! FE is backing away from their poster child that represents all that's wrong with transmission incentives. Too funny!!!
I heard that AEP made mention of PATH in a "hands off" kind of way as well. I guess the PATH parents are too proud to claim the juvenile delinquent they gave birth to.
Overall, from what little I've read, it looks like FERC is getting an earful. The comments against seem to be greater in number, but the comments from the industry are whining much louder. So, let's take a look at who's on what side of the fence:
Against Incentives - States, an couple of mystery financial analysts, some industry groups, and tons and tons of citizens who act as the Transmission Line Savings & Loan.
For Incentives - Energy and transmission corporations, some investment companies. You know, the ones who are robbing the citizen-funded Transmission Line Savings & Loan.
Could it be any more obvious? And if you think FERC still needs to have it explained to them in perfect detail, read the comments of Steven, Shirley and Samuel Smith of Charles Town. The only thing left undone was drawing them a picture.
So, what good comments have you read lately?
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