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
BEFORE THE
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 I. Background
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). II. Comments
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 III. Conclusion
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.

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