Preparing Your Comments to FERC on Transmission Incentives

Here is a link to FERC’s Notice of Inquiry requesting comments on how it conducts its awarding of transmission incentives.

Read the entire notice which provides the history of the incentive system (educational in itself) and then make note of the questions that FERC wants commenters to address.  If you just say “get rid of incentives,” your comments will go in the trash.  Identify a few of the questions, or even just one, and address it clearly with supporting facts from your experience or knowledge.

Here is one I find particularly interesting:

The Commission is interested in receiving comments regarding whether the establishment of criteria for eligibility for particular incentives would enhance regulatory certainty and predictability and serve to further encourage appropriate investment in transmission infrastructure. Should the Commission establish specific criteria or conditions that applicants must meet in order to be eligible for these individual incentives?

One of the ways that FERC could “enhance regulatory certainty” (shorthand for bulldozing state PSCs) would be to award incentives only after a project had received approvals required from all state utility commissions where it was to be located.  Then there is no uncertainty.  Also, the FERC incentive process plays no role in the decision making at the state level.

I am sure that FERC did not intend to get this kind of answer from its industry “stakeholders” but it is an argument that makes a lot of sense to the rest of us who might have ended up paying for a stupid, ill-considered project like PATH, which the power companies themselves withdrew from three state utility commissions after wasting everyone’s time and money for two years.  These kinds of projects should never even come before FERC for incentives in the first place.

Incentives were designed to help with financing, not to bulldoze state sovereignty.

So, this is just one example of you might address one of FERC’s questions from a point of view that FERC will not get from the industry.

It is vital that average citizens insert ourselves into this process if we want to prevent projects like PATH in the future.  We have to stay in the game and engage FERC and the electrical industry on its own turf if we want to defend ourselves from bad policy and bad projects.