• The PSC needs to make energy efficiency investment a priority when evaluating these kinds of projects.  It’s just common sense that we should try to reduce our energy needs first before we require WV rate payers to pay for any new power plant capacity.

• The PSC needs to put WV first.  WV rate payers should not be taking on new rate increases so that an Ohio-based company can shift ownership of its power plants from state to state to increase profits.

• This case offers the PSC a real opportunity to move WV’s power companies away from the financial risks of being overly dependent on a single fuel source.

• FirstEnergy has inflated the cost of the Harrison Power Station to twice its previous book value.  If the PSC does allow some portion of the plant to be sold to WV rate payers, the PSC needs to make sure that the sale price of the plant is reduced to its real book value.

• Mon Power did not seriously evaluate many possible alternatives to this coal plant; instead, they presented a self-serving analysis that justified their decision to purchase this plant to bail out their parent company.

• The PSC should require the power companies to issue a request for proposals to seek out other ways of meeting their capacity shortages, rather than accepting the companies' analysis that purchasing power plants from affiliated companies is the best option for ratepayers.

• FirstEnergy's proposal did not evaluate expanding energy efficiency and demand-side management.  Nationally, investments in energy efficiency cost an average of 3 cents per kWh saved, compared to 7.4 cents per kWh for energy generated by the Harrison plant.

Case No. 12-1655 For AEP (Appalachian Power) only:

• The PSC needs to make energy efficiency investment a priority when evaluating these kinds of projects.  It’s just common sense that we should try to reduce our energy needs first before we require WV rate payers to pay for any new power plant capacity.

• The PSC needs to put WV first.  WV rate payers should not be taking on new rate increases so that an Ohio-based company can shift ownership of its power plants from state to state to increase profits.

• This case offers the PSC a real opportunity to move WV’s power companies away from the financial risks of being overly dependent on a single fuel source

• The baseline energy efficiency scenario assumed by Appalachian Power is much weaker than what AEP is required to meet in Ohio.  The PSC should require greater investment in energy efficiency and demand response from Appalachian Power

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Be sure to reference the PSC case number in your comment (Case No. 12-1655 for Appalachian/Wheeling Power; Case No. 12-1571 for Mon Power/Potomac Edison).

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