Urge FERC to Reconsider Proposed Electric Transmission Incentive Rules (RM20-10-000)

Chairman Neil Chatterjee, Commissioners Richard Glick, Bernard McNamee, and James Danly

Since 2005, the Federal Energy Regulatory Commission ("FERC") has provided attractive incentives that have stimulated significant electric transmission growth. In the mid-Atlantic region alone (PJM region), it has been estimated that consumers have paid a staggering $55.6 billion in transmission costs from 2005 to 2018.   At the same time, there has been a consistent decrease in peak demand coupled with a substantial and steady increase in generation capacity - signaling less of a need to "stimulate" new transmission investments.

State regulators, state consumer advocates, and grassroots groups have all commented that the original 2005 Congressional mandate has been met and that it is appropriate for FERC to revisit its electric transmission incentives.

Despite this, FERC has now proposed "reforms" that will significantly increase incentives that will result in unjust and unreasonable rates in violation of the law.

The proposed rules do not benefit consumers and would only serve one purpose: to increase profit to transmission utilities, all at the expense of consumers.

Please sign this petition urging FERC to reconsider the proposed electric incentive rules.

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To: Chairman Neil Chatterjee, Commissioners Richard Glick, Bernard McNamee, and James Danly
From: [Your Name]

Since 2005, the Federal Energy Regulatory Commission ("FERC") has provided attractive incentives that have stimulated significant electric transmission growth. Studies by the Department of Energy and other data have shown that there have been significant increases in transmission investments. In the mid-Atlantic region alone (PJM region), it has been estimated that consumers have paid a staggering estimated $55.6 billion in new transmission costs from 2005 to 2018.

At the same time, in this same region, there has been a consistent decrease in peak demand coupled with a substantial and steady increase in generation capacity.

As a result, in response to FERC’s 2019 Notice of Inquiry regarding incentives for electric transmission investment, non-utility related organizations, including state regulators, state consumer advocates, and grassroots groups, have commented that they believe the original Congressional mandate as codified in Section 219 of the Federal Power Act has been met and that it is appropriate for FERC to revisit its generous electric transmission incentives with the thought of narrowing these incentives if not eliminating them.

Specifically, Section 219 was very explicit that all rates approved under the section, including any new rules, must be “just and reasonable and not duly discriminatory or preferential.”

Despite this, FERC has now proposed "reforms" that will significantly increase incentives that not only don't ensure reliability and reduce the cost of delivered power but will also result in unjust and unreasonable rates in violation of Section 219.

The proposed rules do not benefit consumers and would only serve one purpose: to increase profits to transmission utilities, all at the expense of consumers.

We respectfully urge the Commission to reconsider these proposed incentives (Docket RM20-10-000) for electric transmission investment and to not adopt them.