Microsoft word - er11-3064.doc
April 1, 2011 Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: Trans-Allegheny Interstate Line Company; Docket No. ER11-3064-000 Dear Madam Secretary:
Attached for electronic filing are Comments of Exelon Corporation.
A. Karen Hill Attorney for Exelon Corporation
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Trans-Allegheny Interstate Line Company
) Docket No. ER11-3064-000
COMMENTS OF EXELON CORPORATION
Pursuant to Rule 211 of the Federal Energy Regulatory Commission’s
(Commission) Rules of Practice and Procedure, 18 C.F.R. § 385.211 (2010) and the
Notice of Filing issued in the above-captioned proceeding on March 14, 2011, Exelon
Corporation (Exelon) submits these Comments on the March 11, 2011 filing submitted
by Trans-Allegheny Interstate Line Company (TrAILCo).1
On March 11, 2011 TrAILCO submitted a revised Attachment H-18A to the PJM
Interconnection, L.L.C. (PJM) Open Access Transmission Tariff (Tariff) modifying
TrAILCo’s existing transmission cost of service formula rate (Formula Rate) to allow the
recovery of prudently incurred costs associated with abandonment of a portion of the
Trans-Allegheny interstate Line (TrAIL) Project.
1 Exelon timely filed a document-less intervention in this docket on March 15, 2011. Exelon is a holding company, located in Chicago, Illinois, which owns Commonwealth Edison Company (ComEd) and PECO Energy Company (PECO). Together ComEd and PECO own transmission and distribution systems and serve over five million retail electric customers in northern Illinois and the Philadelphia area. Exelon also owns Exelon Generation, LLC (ExGen), which owns or controls approximately 30,000 MW of generating facilities. Exelon Power Team is the wholesale marketing division of ExGen and is a leading power marketer throughout the country. These Exelon subsidiaries are members of PJM Interconnection, LLC (PJM).
TrAILCo’s filing seeks recovery of abandonment costs incurred in connection
with a portion of the TrAIL Project. Exelon takes no position with regard to the prudence
of TrAILCo or the reasonableness of the costs that it seeks to recover. Exelon is
concerned, however, as to who will bear any abandonment costs that ultimately are
recovered. In its most recent annual update of the cost allocation of RTEP projects in
Docket No. ER11-2578,2 PJM removed any cost allocation for project b03213 from
Appendix A of Schedule 12.4 While this filing changes TrAILCo’s formula rate to allow
recovery of abandonment costs, it does not make clear which PJM load zones will bear
those costs. Exelon requests that the Commission clarify the mechanism for identifying
those loads that should pay the abandonment costs that TrAILCo seeks to recover.
Some portions of the project identified in TrAILCo’s filing as having been
abandoned were planned to operate at 500 kV and above; other abandoned facilities
would have been below 500 kV.5 Different cost allocation methodologies may apply to
these facilities, depending on their voltage. However, Exelon believes it is premature to
address at this time what would be a just and reasonable allocation of any such costs,
because no cost allocation proposal has been filed. Exelon further notes that while
Opinion No. 494 prescribes the methodology for the allocation of the costs of completed
facilities, the Seventh Circuit Court of Appeals remanded that decision to the
Commission for its further consideration. Proceedings in the remanded matter, EL05-
2 The Commission accepted this filing subject to the outcome of the proceeding in Docket No., ER05-121 in a Letter Order dated Feb. 1, 2011. 3 Upgrade b0321 encompasses the Prexy Facilities that are the subject of the TrAILCo filing. See
TRA-100, page 2 (identifying Prexy Facilities as b0321.1, b0321.2 and b0321.3). 4 Compare
pages 411-412 of PJM filing in ER11-2578 (effective Jan. 1, 2011, no b0321) with
page 60 of PJM filing in ER10-529 (effective Jan. 10, 2010). 5 See
TRA-100, page 2.
121-006, have been concluded and the matter is awaiting action by the Commission.
To the extent that any costs of abandoning the TrAILCo project are to be allocated in
accordance with Opinion No. 494, Exelon requests that approval of the TrAILCo filing
that is the subject of this docket be subject to the outcome of the Commission’s decision
For the foregoing reasons, Exelon respectfully asks that the Commission direct
that TrAILCo or PJM file a proposed allocation of the abandoned costs and provide that
the allocation of the abandonment costs at issue in this proceeding be subject to the
outcome of the remand proceeding in docket EL05-121-006.
Certificate of Service
I hereby certify that I have this day served the foregoing document upon each
person designated on the official service list complied by the Secretary in this
Dated at Washington, D.C. this 1st day of April 2011.
CRÓNICA DEL XIII CONGRESO INTERNACIONAL DE NUMISMÁTICA El XIII Congreso Internacional de Numismática, primero que se celebra enEspaña desde su creación en 1891, se ha celebrado con todo éxito en el Palacio deCongresos del Paseo de la Castellana de Madrid entre los días 15 y 19 de septiembrede 2003, bajo la presidencia de honor de SS. MM. los Reyes de España, el Patroci-nio del Minis
Why Not Give Me an Antibiotic, Doctor? By Dr. Joseph Mosqura, MD DABIM Medical advice about infections has changed. Years ago, parents were told that children with ear infections or sore throats needed to take antibiotics “just in case.” Then we discovered that most children (and adults) recovered just as quickly from these infections without antibiotics. That’s because the drugs only