Sorry, you're going to have to do your own analysis on this one.

A story in the New Haven Register reports that the ruling is a setback for New England ratepayers.

Here's the dissent of Commissioner Norris mentioned in the article:

He's concerned, "...that this determination subjects consumers to unjust and unreasonable rates in this proceeding and potentially in future ROE proceedings."

Here's a geekier article about it.

Here's the entire Order, for those with "super geek" status.
EUCI and its stable of vacationing utility executives are going to be partying it up at the Roosevelt Hotel in midtown Manhattan next month. 

So, what pretense are they using this time?  "Strategic Communication for Transmission Projects."  Well, at least they have abandoned the charade that their public relations fabrications are about "participating with the public" this time.

Instead, it's all about manipulating public opinion, or so they think.  Topics include:
How Utilities Effectively Manage the Media

Industry experts will discuss how to frame and "sell" transmission projects as the beneficial investments that they are on behalf of the customers. Attendees will learn how these energy executives keep messaging succinct, consistent and well-positioned. Panelists will discuss successful strategies and tactics for interacting with the media.
Does this include a lesson in gagging and tying opposition leaders up in the corner?  Otherwise, they're only fooling themselves.  The opposition also knows how to "effectively manage the local media," and they know how to do it better, without resorting to threats and lies.

Is this really about educating the public about the truth and reality of transmission, or is it about "selling" a fantasy version of transmission that doesn't include any detriments or drawbacks?  Sorry, that ship has sailed.  The public simply doesn't believe you anymore.  And reporters hate you and all the smoke you blow up their ass.

And speaking of "selling," I'm starting to wonder if EUCI is more about selling the products and services of its "instructors" to conference attendees:
EMF: What the Public Wants to Know and Why It Matters to Your Project

Public concern about electric and magnetic fields (EMF) and related potential health effects began in the late 1970s in association with higher voltage transmission lines and desk top computers. While concern about the latter has largely diminished, concern about EMF from transmission lines and substations continues and is sometimes a major issue in the siting and permitting of these facilities. Our experience demonstrates that presenting technically accurate comparisons of exposures from existing and proposed facilities provides a good context for communicating with the public. Sharing the results of experimental and epidemiology research studies and the perspectives of national and international health and scientific agencies is an effective method to assuage public concern. This session will teach you how to get the science right in your public outreach messages about EMF.

William H. Bailey, Ph.D., Principal Scientist, Center for Exposure Assessment & Dose Reconstruction, Exponent
I think Dr. Bailey has no idea what the public really wants to know about EMF, but he probably does know why it matter$ to "you."

Here's what the public really wants to know about EMF:

The professional opinion of a local physician, not the opinion of a company-paid, industry-funded "scientist."  Sorry, transmission developers, you just can't buy local credibility.

But, the real fun is at the "post-conference workshop" where the blind will lead the blind in this exercise:
Utilizing Mediation and Negotiation Skills to Diffuse Project Opposition


Inevitably, utility infrastructure projects draw some opposition, in person or through social media. This workshop is designed to identify the real issues behind project opposition, and to utilize mediation and negotiation strategies to gain support. Participants will explore the dynamics of conflict, perceived power imbalances, communication skills, and neutral positioning. Utilizing skill building exercises and strategies for reaching agreements, attendees will learn how to be an effective medium between the project owner and project communities. You will also learn effective strategies and tactics, and share in resolving real opposition issues from current and past projects. You are encouraged to bring your current project issues to develop a resolution strategy.

Learning Outcomes

Identify the concerns behind opposition
Evaluate when and when not to utilize social media to counter opposition attacks
Demonstrate how to properly communicate your message through application and critique.

Anticipating Opposition

Knowing your demographics and what is important to your project community
Understanding how to communicate project needs
Utilizing data to create visuals showing system constraints, demand, growth
Educating the opposition through clearly understood messaging

Opposition Working Groups

Seeing your project from the view of the opposition
Working group structure

Resolution Strategies

Using project benefits to the communities advantage
Formulating the strategy of "give and take"
Evaluating how to answer questions such as:
Why not go underground?
Will this harm my property value?
Should we be concerned about EMF?
Developing resolution strategies for your current project opposition

"Seeing your project from the view of the opposition?"  And how many transmission projects has EUCI's instructor opposed?  My guess would be none.  There they go again, attempting to teach a subject they know nothing about.

I do like the new theme I see running through all EUCI's more recent transmission opposition workshops, though.  The acknowledgement that opposition has changed, the public is more knowledgeable than before, and that transmission developers are embarking on a strange, new world where their opposition is increasingly organized, strategic and successful is a nice change of pace.  Because the first step on the road to recovery is admitting you have a problem, right, EUCI?
Can't resist this...

In Akron, Ohio, Tony the Trickster wants to increase taxes to provide for more "public safety."  Maybe he needs a few more cop cars out in front of Casa de Alexander to keep his employees away?
Whatever the reason, Tony is tossing $50K into the effort and he held a "private" breakfast to talk about it this morning.
The breakfast meeting will include “the standard list of characters,” he said when asked who will attend.
Hmmm... standard list of characters.

Is he talking about this list of characters?

Or maybe he means these characters:
But in reality, he probably just means these characters.
I hope Tony's serving big, fluffy, cream pies...
Nearly 10 years ago, PJM's management made a very poor choice approving Project Mountaineer, a scheme to build more than $3B worth of new transmission in order to increase the transfer of 5,000MW of coal-fired generation to the east coast.  Project Mountaineer caused PJM to approve four new high-voltage transmission projects and add them to its RTEP:  TrAIL, Susquehanna Roseland, PATH and MAPP.  Only two of these highly controversial projects were ever built, and at a very high cost.  The other two were abandoned without ever turning a shovel of dirt.

PATH was re-routed within months of being introduced to the public, because PJM's approved plan for it called for "twin" 500kV circuits through densely populated, high-growth areas of West Virginia's eastern panhandle, northern Virginia, and Maryland's Washington, D.C. suburbs.  It just wasn't physically and politically possible to construct the project.  PJM's determination of the "constructability" of PATH was wrong.  Even its second choice of a single 765kV line through the area failed.

And PJM hasn't gotten any smarter about constructability since.  Its first major transmission project since the PATH/MAPP failure is also destined to "constructability" failure.  PJM recently selected PSE&G's proposal for a new 500kV line to parallel an existing line in Salem County, New Jersey to solve its Artificial Island problem.  PJM claimed its decision was based on the "constructability" of PSE&G's project.

So, what standard did PJM use?  PJM hired a company that does work for the companies bidding on this project to do a "Constructability Study."

The study accounts for environmental permitting, historical commission review, federal environmental review, and a host of other "risks."  It gave little moment to state utility commission review and permitting, and paid absolutely no attention to possible public opposition and its impact on permits necessary from local government.

I guess PJM and GAI Consultants have already forgotten what killed the PATH project they both had a hand in.  GAI opines that paralleling existing transmission lines will dampen opposition because there's no need to involve "new" landowners.  Right... because transmission lines are like potato chips... one is never enough!

The routing study and mapping shows urban and residential areas being crossed, and at one point the line runs practically right over top of a school.  Although all projects needed to acquire new right of way adjacent to the current one, GAI and PJM reason that PSE&G has an advantage here because of some old agreement over ownership of transmission assets.  I just don't see this agreement being helpful convincing landowners to agree to expand the current right of way.  Maybe PJM has forgotten what happened when TrAILCo attempted to utilize old right of way in Pennsylvania?  In that instance, trying to force old agreements on new landowners using unscrupulous land agents blew up in TrAILCo's face and most likely contributed to its eventual denial by the PA PUC.  In the end, TrAILCo had to abandon that old right of way and give it back to the landowners. 

The selected project also proposes an overhead river crossing in a very busy shipping lane, instead of the submarine crossing proposed by other projects.

This is a public opposition bonfire in the making!

So, what else could PJM have done here?  What other projects were in the running?  Projects choosing a route through Delaware were evaluated for "constructability" by a different company that actually considered public opposition, and none of that was very encouraging.  All projects will garner public opposition, some more than others.  DUH.

Damned if you do, damned if you don't.

But, wait a tick here.  There's one project on PJM's bid list that doesn't seem to have been evaluated in either "constructability" report.  I guess PJM batted it aside instantly, like a distasteful mint.

Atlantic Grid (yes, the ones who have been patiently trying to construct an offshore backbone transmission line to gather offshore wind generation and funnel it to shore at strategic locations) submitted something called the Garden State Reliability Project.
  It looks like this project was going to do something entirely different than the rest of the contenders.

The Artificial Island-related challenges to grid reliability and operational flexibility that PJM describes in its Problem Statement can be solved with the Garden State Reliability Project (GSRP), a proposed voltage source converter (VSC) high voltage direct current (HVDC) transmission system that connects Artificial Island to the Cardiff AC Substation near Atlantic City, New Jersey. GSRP has the capacity to controllably transmit 1,000 MW of power on its approximately 60-mile underground circuit. GSRP also incorporates static VAR compensator (SVC) facilities. The project is estimated to cost $1,012 million and to be in service by December 31, 2018.
Not only was this project going to fix PJM's little Artificial Island problem, it was also going to tie into Atlantic Grid's New Jersey Energy Link to provide a way to move nuclear power into the congested northern New Jersey load zone.  It would also provide backup, baseload power to balance the eventual offshore wind generation's variability.

But, Atlantic Grid's GSRP was proposed to cost 4 times as much as PJM's favored project.  However, GSRP provided many other benefits the other project didn't, such as black start capability for Artificial Island, and it was designed to meet future needs, instead of simply fixing today's little problem.  Low cost may be the easy choice for today, but sometimes it's just not as efficient.

PJM's "low cost" choices presume that a select set of landowners must be forced to sacrifice their private property for the good of society.  When is the rest of society going to make a sacrifice for its own good?  Adequately compensating landowners and/or building higher cost projects that don't require as much sacrifice from host landowners should be a sacrifice society is willing to make for its own good!  Want cleaner power?  Want your lights to stay on?  You need to pay for it, not some other landowners miles away who are not benefiting from the project.

And you know what was really innovative about Atlantic Grid's project?  It was completely underground and routed along road rights of way!  Minimal sacrifice for host landowners, minimal public opposition, minimal risk, minimal time to complete.
Another key GSRP project objective was to demonstrate timely constructability with a practical right of way (ROW) approach and low construction and environmental impact. GSRP is distinguished from high voltage AC line solutions to the grid reliability and operating issues at Artificial Island because GSRP has a more predictable in-service date. GSRP’s HVDC cable system would be buried underground in state and local road ROW, rather than being constructed as an overhead transmission line. Accordingly, building GSRP requires simple rights of access to existing road ROW granted by public entities. In comparison, AC overhead transmission solutions will require new or expanded ROW acquisition involving tree and brush clearing, high towers, aesthetic and environmental impacts, public opposition and litigation. All of these challenges associated with overhead lines cause less predictability and greater cost.
Instead, PJM seems to prefer continuing its old status quo of selecting projects proposed by its incumbents that are environmental, permitting and public opposition nightmares.  And we all pay for PJM's mistakes.
After enough wrangling to make a cowboy cry, the Senate Energy and Natural Resources Committee confirmed the nomination of Norman Bay as Chairman of FERC... as long as he keeps the training wheels on his regulatory tricycle for the next 9 months.

Bay can be a FERC Commissioner, as long as Acting Chairman Cheryl LaFleur gets to continue to "act" for the first 9 months of Bay's tenure.

RTO Insider has the best coverage of today's events here.

RTO Insider notes that our own Plastic Senator Joe Manchin sold out in a hurry.
Among those who had expressed concern over Bay’s limited energy policy experience was Manchin, who helped sink the bid of Obama’s previous nominee, former Colorado regulator Ron Binz.

That sparked a flurry of negotiations over the last several days among the White House, Murkowski and Energy committee Chair Mary Landrieu (D-La.), which resulted in the president’s concession not to appoint Bay chairman immediately.
Poor, old Plastic Joe.  Some days, he just can't seem to make up his mind.
I came across an interesting FERC filing the other day.  It's about something called "unreserved use," which is kind of a geeky, complicated subject, but the real issue here seems to be FERC's deference to one of its regional transmission operator pets, and a contradiction about whether specific information should be public or privileged.

Now where else has FERC had issues with that lately?

Unreserved use is failing to reserve transmission before utilizing it, so planners cannot account for the usage until they see it in real time, some call it "leaning on the system."  In most tariffs, a company gets a 200% penalty for the extra stuff it puts on the system.  FERC has asked that RTOs annually account for those penalties.  FERC also wants the RTO to distribute the penalty amounts to non-offending customers, so it's a two-pronged incentive to follow the rules.

In FERCenese, here's how it's supposed to work:
In Order No. 890, the Commission required each transmission provider to report its operational penalty assessments and distributions in an annual informational filing. The annual filing must contain the following information: (1) a summary of penalty revenue credits by transmission customer; (2) total penalty revenues collected from affiliates; (3) total penalty revenues collected from non-affiliates; (4) a description of the costs incurred as a result of the offending behavior; and (5) a summary of the portion of the unreserved penalty revenue retained by the transmission provider. Each transmission provider must report on its penalty assessments and distributions in an annual compliance report submitted on or before the deadline for submitting its FERC Form No. 1.
Sounds rather routine, right?  Except that some RTOs make their compliance filing as a public filing, but MISO has decided that its compliance filing is privileged because:
MISO contends that this type of information could be used by other "MISO market participants to discern trading patterns, and even trading strategies, adopted by other MISO market participants.
Well, yee-haw, cowboys!  SPP files this information publicly!  Cue the crooked traders.... And PJM has NEVER even made a compliance filing.  FERC has so many clear rules it doesn't try to enforce, yet sticks its nose into the murky but headline grabbing world of supposed market manipulation where it doesn't even know its own rules.

Just what IS it about MISO's unreserved use filing that can't stand public scrutiny, anyhow?  Something doesn't add up here...
Clean Line Energy Partners is getting increasingly desperate as its "business plan" to build 3,000 miles of high voltage DC power lines across the country begins to come apart at the seams.

Clean Line's Plains & Eastern project stretching from Oklahoma to Tennessee thought it would help itself to Section 1222 of the 2005 Energy Policy Act and arranged a cozy RFP from the DOE that coincided with its intent to build its project.

Except Clean Line's project does not fit the plain language in the statute.

In an attempt to remedy its failings, Clean Line facilitated a secret flurry of form letters to U.S. Department of Energy Secretary Ernest Moniz from wind energy companies that stand to profit from the project.  The form letters urge Secretary Moniz to approve Clean Line's Section 1222 application.

But the comment period, and the letters, were conducted IN SECRET.  The citizens and landowners affected by Clean Line's use of Section 1222 were not afforded an opportunity to comment.  In fact, the citizens have been continually told by DOE personnel that their only opportunity to weigh in on this matter is through the DOE's Environmental Impact Statement.

This is being done despite the fact that DOE is accepting letters in support of Clean Line that have nothing to do with the EIS.

Don’t let Clean Line’s lies be the only voice Secretary Moniz hears before he makes this important decision!  It is imperative that you tell Secretary Moniz not to approve Clean Line’s application NOW.  He wants to hear from YOU!

Send your letters to: 

The Honorable Ernest Moniz, Secretary
U.S. Department of Energy
1000 Independence Ave., SW
Washington, DC 20585

Or Call him:  202-586-5000

Send him a fax:  202-586-4403

Send him an email:

Comment on his Facebook page:

Send him a Tweet:

Let’s bombard Secretary Moniz with REAL comments from REAL people and drown out the comments Clean Line’s toadies submitted!  Your voice will make a difference! 

If you need help composing your comments, email me!
Never underestimate the power of the citizens to find stuff out!

A citizens' group opposing Xcel's Pawnee - Daniels Park Transmission Line Project came across some interesting information a couple weeks ago.

The citizens uncovered a letter the Douglas County School Board sent to the Colorado Public Utilities Commission that urged the CPUC to "approve the project."  The letter prattles on about economic growth, increased electric use, and reliability, all things not within the expertise of the Douglas County School Board to determine.

The letter is signed by Board President Kevin Larsen, but none of the other school board members remembered approving it, or even discussing it.

Why would the School Board write this letter?

Maybe because Board Member Douglas Benevento, who is listed on the letter as Vice President of the school board, is also Vice President of Public Affairs for Xcel?

Imagine that!  What a coincidence!

Channel 7 reports that Benevento has "recused himself" from any discussions of Xcel and that he will not be in attendance to face the music tonight when the citizens of Douglas County show up at the school board meeting to ask the following questions:

1) Why would the school district get involved at all?
2) Did the district check with its constituents in the affected areas before endorsing?
3) Was this a unanimous decision made by the board?
4) What analysis of the project did the board undertake to understand the need and impact of the project before endorsing?
5) What expertise did the board utilize to make this decision?
6) What meetings with Xcel and its representatives has the board (or school staff) held regarding Xcel's proposed plan, when were those meetings held and what was the substance of those meetings?
Ut-oh, Xcel!  When are power companies going to get with the program and realize this ain't their Daddy's transmission line battle?

Opposition has evolved and the rules have changed.  Forever.

UPDATE:  Last night, the school board voted 4 to 2 to rescind the letter it had sent to the PUC. In its place, it will send a letter saying they don't want the power lines near schools. We believe this is a huge (and quick) victory!

Several Halt the Power Lines supporters were there and two spoke, including Colonel Curt Dale.

Board president (Kevin Larsen) reported that when he signed the letter in early May, he thought it related to a different matter and signed it without anyone else seeing it beforehand. He voted to let the letter stand as sent to the PUC. He said he likes and defended Xcel's proposal (as long as they keep the lines a safe distance from schools). We asked what about the kids in residential neighborhoods. Director Richardson, who was the second vote to let the letter stand as is, later said not having it close to schools (but close to residents) was a matter of density. I'm pretty sure, unbelievable as it is, that he actually used the word "density." Nettled, he also said he might personally send a letter to the PUC endorsing the project. (For what it's worth, he works for a gas pipe company that has many business dealings and business arrangements with Xcel.)

Voting to rescind the letter were directors Geddes, Reynolds, Robbins and Silverton. The four felt that the school board had no business in the matter, except ensuring the power lines weren't near schools. (Mr. Benevento was not at the meeting.)
The Pollyanna Planners of PJM Interconnection are at it again.  Today, PJM announced it had made a decision about the building of a new 18-mile 500kV transmission line in Salem County, New Jersey.  As the first project awarded under FERC's new "competitive" transmission building system, PJM proved that old habits die hard by awarding the $250M project to incumbent transmission builder PSEG. 

PJM kicked a plan by independent transmission builder LS Power to the curb.  LS Power's plan was to build a 5.5-mile 230-kV line and a new transformer and switchyard by mid-2017 for $116 million to $148 million.  But, PJM's delusions of grandeur made it decide in favor of a longer, bigger and more expensive plan proposed by one of its incumbents.

PJM says that siting and permitting prospects were one of several factors it considered when making the recommendation, although the selected project may have issues securing a permit for a river crossing and will cross the Supawna Meadows National Wildlife Refuge, the Alloway Creek Watershed Wetland Restoration Site and the Abbotts Meadow and Mad Horse Creek Wildlife Management Areas. 
PJM officials said that while this solution was comparable to other projects based on such factors as cost, schedule and the ability to address the reliability concerns, the Hope Creek-Red Lion 500-kV line was superior in terms of constructability.
Seriously, PJM?  Who's giving you advice about "constructability?"  The same geniuses who thought PATH and MAPP were good ideas?  Those two projects turned out not to be so "constructable" after all, and have left PJM ratepayers footing a bill for more than $350M for projects that never even put a shovel in the ground!

The New Jersey Board of Public Utilities said PJM’s analysis of the 500-kV option underestimated likely public opposition.

Ya think?  Just because the new transmission line parallels an existing one does NOT mean that affected landowners will welcome it with open arms.  In fact, these landowners already know what it's like to live with a transmission line across their land, and feel they have already made the ultimate sacrifice for "the public good."  They will NOT want another one, and will fight tooth and nail to kill this project.

And, guess what?  They'll have plenty of help from other transmission opposition groups that have perfected the art of public opposition.  After all, we've had some of the best teachers in the world to show us all the ins and outs of transmission project strategy, and we like to "pay it forward."

So, if you're a landowner in Salem County, New Jersey, who already has a 500kV transmission line in your backyard, check out the map at RTO Insider to see if you're one of "the chosen."  I am looking forward to meeting you!
FirstEnergy's Potomac Edison and Mon Power subsidiaries finally got around to filing their testimony in the rate increase case last week.  As instructed by the WV PSC, the company has added the additional cost of rectifying its own failure to the increase it is seeking.

Monthly meter reading will increase customer rates an additional $7.5 million annually, or 1.35% for residential customers(1.57% for non-residential).  This increase will be added to the already proposed 13.95% base rate increase, and additional estimated increase for coal plant retrofits of another 2%.  Total rate increase proposed by FirstEnergy for its West Virginia residential customers?


According to Testimony of Raymond E. Valdes filed last week, FirstEnergy's 2013 cost of meter reading was just over $5M per year.  Dividing that number by the number of actual meter reads performed resulted in an average cost of $1.99 per meter read.  But FirstEnergy can't simply double the costs because its number of meter reads compared to estimates is not equal, even when the annual read customers are removed from the equation.  When numbers are actually put on paper, it turns out that FirstEnergy was not actually reading meters every other month, or half the time, as required.  FirstEnergy was reading meters much less than the required every other month.  Maybe the WV PSC should have asked for these numbers during the general investigation and simplified everything?

Actual Meter Readings in 2013:          2,238,832
Estimated Readings in 2013:              2,894,376

If the company had been reading meters every other month as it was supposed to, then these two numbers would be equal.  This is the plainest picture you're going to get of FirstEnergy's failure.

So, anyhow, Valdes used the $1.99 reading cost to calculate a total incremental cost to switch to monthly meter reading of $6.4M.

But, wait, the company needs to add an additional $1,074,173 in "transition costs" to rectify its own meter reading mistake.  FirstEnergy describes these costs as:  "estimated additional costs the Companies will incur related to the conversion to monthly meter reading."  The company proposed to recover this extra million over a 3-year period, so that it can earn interest on it (at your expense, of course).

This brings your additional cost to read meters monthly up to:


And that is a clearest picture you will get of how your Public Service Commission has failed to protect your interests during its perfunctory "investigation" of FirstEnergy's customer abuse.

The PSC clearly found FirstEnergy to be at fault in the investigation.  But, instead of punishing the company for its failure, the PSC has punished the customers who were injured by the failure.  As my friend Kery says... when is the failure to perform under a contract ever the fault of the party who was injured?  FirstEnergy failed to perform.  They should be liable to the parties injured by their action.  End of story.

Except, this is West Virginia, where our PSC behaves like a poodle on a leash held by Ohio energy conglomerates.  Look up "regulatory capture."

The PSC could have made some token attempt at fairness in its general investigation order.  It could have ordered FirstEnergy to absorb the first year's incremental additional cost ($7.5M).  It could have ordered FirstEnergy to absorb the $1M transition costs, instead of putting them on the backs of struggling ratepayers for three years.

But it didn't.  FirstEnergy was rewarded for its failure.  Rewarded for injuring YOU, the customer.

So, what can you do?  Tell the PSC what you think!  You can submit an online comment here.  Select "high profile" case number 14-0702-E-42T from the drop down list on the comment form.

As we move forward with this rate increase case, there will also be opportunities to voice your concerns in person during various public comment hearings around the state.  Stay tuned...