"This assertion should be seen for what it is - clear and convincing evidence that Century's parent itself lacks confidence that Century Aluminum of West Virginia, Inc. can successfully operate a restarted Ravenswood plant," the filing said.
"In other words, Century's parent is unwilling to 'put its money where its mouth is.' "
In its response to the PSC ruling, Appalachian Power asked that the PSC require Century Aluminum Corp. - not just subsidiary Century of West Virginia Inc. - to put forth a letter of credit that would cover any shortfalls should the subsidiary go out of business.
Century said that would be too much financial risk.
Appalachian Power said it is now apparent that Century has no interest in bearing any type of long-term risk to operate the plant.
"It will have recouped its start-up investment within three years and, after that, it seems willing to let the prospects of (Century of West Virginia) rise and fall with the global aluminum market, confident that the risks of low aluminum prices and failure of the venture will fall on the shoulders of APCo, APCo's other customers, and West Virginia taxpayers, workers, and retirees," the APCo filing said.
Appalachian Power asked the PSC to reject Century's alternatives.
"The special rate mechanisms which Century favors are not remotely evenhanded: they confer subsidies of unwarranted magnitude on Century; they transfer the business risks of Century to an unwarranted degree to APCo and its other customers; they impose unreasonable financial burdens on APCo and its other customers; and they relieve Century and its parent of any practical responsibility for the potentially immense revenue shortfalls that Century's special rate proposals could produce," the filing said.
Now that parties in the case have responded, the PSC can decide if it wants to take further action to clarify its initial ruling.
While Century has a right to have its case reconsidered, it appears unlikely the PSC will modify key aspects of the special rate structure it laid out last month.
Commissioners made clear to Century that they would not shift any additional costs onto other ratepayers. When they extended Century's deadline to file reconsideration motions, they also indicated they were not open to reconsider this shift.
Commissioners must review all the filings that have been submitted before deciding whether to take further action.
Contact writer Jared Hunt at jared.h...@dailymail.com or 304-348-5148.