FERC Filings

Initial Post Hearing Brief of EPSA re: The New PJM Companies, American Electric Power Co. and Central and South West Co.

Findings and Conclusions

1. The integration of AEP into PJM will enhance the reliability of the transmission grid and provide cost savings to all market participants. AEP’s voluntary commitment to join PJM is designed to obtain economical utilization of facilities and resources in the Midwest and Mid-Atlantic area and will result in increased reliability, lower costs, and the development of robust competitive wholesale power markets.

2. The laws, rules or regulations of Virginia and Kentucky are preventing AEP both from fulfilling its merger commitment to join an RTO and from complying with Order No. 2000. Any additional delay resulting from the actions of Virginia and Kentucky only serves to further impede the successful integration of AEP’s transmission system into PJM and delays the resultant benefits to other states in the region.

3. The provisions of Kentucky and Virginia laws are not designed to protect health, safety, welfare or the environment, or to conserve energy, or designed to mitigate the effects of emergencies resulting from fuel shortages. These laws were adopted to override Commission policy determinations and do not fall within the exemption in Section 205(a).

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