Statement from APPA Senior Vice President, Advocacy & Communications and General Counsel on the Notice of Proposed Rulemaking on Electric Transmission Policy Under Section 219 of the Federal Power Act
The American Public Power Association (APPA) supports investment in America’s transmission infrastructure and Federal Energy Regulatory Commission (FERC) policies that effectively promote such investment. Unfortunately, the majority of the changes to FERC’s transmission incentive policies proposed in the NOPR will likely result in unjust and unreasonable outcomes, raising transmission costs without ensuring that consumers see increased benefits. Existing FERC policies pertaining to project-specific incentive applications are sound and there is no compelling reason to change them. This current framework adequately balances the interests of investors and consumers when awarding incentives. Further, there is no evidence that investment is being withheld for lack of incentives. APPA also vigorously opposes FERC’s proposal to double the current equity return adder for participation in regional transmission organizations and independent system operators. This proposal would provide transmission owners with an unjustified windfall at the expense of transmission customers. As transmission costs continue to rise, public power utilities can hardly afford to incur additional costs associated with unnecessary transmission incentives. And the NOPR fails to demonstrate that these additional costs will be exceeded by their benefits to electric customers.