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TESTIMONY  DELIVERED  BY  MARCHANT  WENTWORTH
DECEMBER  17,  2014

Madam Chair and members of the commission:

My name is Marchant Wentworth and I reside at 903 Hamlin Street NE in Washington, DC. Thank you for the opportunity to present testimony on the application of Exelon to merge with Pepco as put forth as Formal Case No. 1119. I am presenting this testimony as a private citizen. 

I strongly urge the members of this commission to reject the proposed merger agreement because it will pose excessive risk to the ratepayers of the District of Columbia. I will submit a detailed statement for the record supplying the background to my statement. This evening I present a brief summary of the reasons that I believe this merger poses unacceptable risks to District ratepayers and why the commission should reject this application.

  1. Testimony from Exelon indicates that as much as 40 percent of Exelon’s pro forma 2015 earnings might be derived from sources that would not be regulated by this commission. Financial losses in these businesses could force Exelon attempt to recover money from district ratepayers in order to keep its stock price up and satisfy its shareholders.
  2. According to Exelon’s 2013 10-K filing, nuclear power furnished 57 percent of the company’s electricity supply. Nuclear power plants are vulnerable to increased costs of generation due to:
  • Additional costs related to safety improvements needed as a result of the Fukushima nuclear disaster; 
  • Additional costs related to the storage of nuclear waste;
  • Additional costs related to the needed upgrades in the use of cooling water under EPA’s 316(b) rule including risks from the effects of climate change on cooling water temperature;
  • Additional risks as a result of Exelon’s nuclear fleet lack of competiveness in the market place; particularly in regard to low natural gas prices, energy efficiency including demand response and renewable energy;
  • Additional risks relating to expiring operating licenses;
  • And lastly, additional costs associated with decommissioning nuclear power plants.  

The District of Columbia is presently enjoying a large number of residential solar projects, due in part to renewable electric standards enacted in the district and elsewhere in the PJM generating territory. These projects will substantially benefit District ratepayers and make our local electric grid more resilient. The role that Pepco has played in this activity, while far from perfect, has been helpful in reducing the barriers for distributed energy.

In contrast, Exelon has demonstrated its resistance to increasing the use of renewable energy and has actively campaigned against tax credits and other incentives that would actively support its increased use.    

For these and other reasons, I urge the members of this commission to reject Exelon’s merger agreement.  

Thank you for the opportunity to present this statement.  I would glad to answer any questions you may have. 
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