I am writing to express my strong opposition to PJM’s 2022 Window 3 RTEP “solution” that will put an enormous burden on PJM ratepayers in the Mid-Atlantic area. The expected $5.4 Billion dollar cost to be shouldered by ratepayers to support an industry that includes some of richest companies in the world is an abuse of PJM’s power.
At the September 5, 2023 TEAC meeting, I asked if PJM had engaged in conversations with Virginia state officials about their plans to advance dependable, dispatchable generation in Data Center Alley as an alternative to a transmission solution only approach. The negative, volatile reaction of your employees running the TEAC meeting was essentially to squash any and all ideas that PJM would ever have that type of conversation with state officials. Certainly, the Data Center Alley companies build of back-up generation on site in the form of diesel generators is apparently fine with Virginia officials. So again, please explain why PJM will not have that conversation? Your own Market Monitor has told PJM over and over again that a process to compare the building of generation vs. building transmission should already be in place.
The only two states in PJM’s Mid-Atlantic region that have excess generation capacity to send to Data Center Alley are Pennsylvania and West Virginia. What happens to PJM’s “solution” when the Biden Administration fulfills their promise to shut down all the coal-fired plants in the country? What happens when PA and WV are tapped out with their excess generation capacity? How close are we to that tipping point? Will this 2022 Window 3 solutions be for naught when there is no power to send?
Is PJM sure this time, that the transmission that you are ordering will be the last time that the same communities are asked to shoulder this burden? Wasn’t it just in 2017 and again in 2021, that the MD/PA border region in Harford County, MD and York County, PA experienced backbone transmission projects? What financial benefit does our area receive in tax revenues from Data Center Alley? NONE! If the State of Virginia wants to keep receiving the tax revenues from data center development, then they need to man up and build the necessary generation to support this type of development. The same communities should not be asked once again to shoulder this burden.
The reality is, that green energy cannot provide sufficient electricity to meet the needs of our Country at this time. States with ambitious green agendas are being disingenuous to their citizens. Shutting down reliable, dispatchable generation on the hope that wind, solar and battery storage can be effective in supplying electricity is a fool’s errand that will only increase electricity costs for ratepayers. ​

PJM knows that and should make it clear to the States that doing so will result in widespread loss of electricity for its 65 million ratepayers. Certainly, the 11-30-2023 OPSI letter you received clearly outlines the grave concerns associated with the 2022 Window 3 solutions and the need for reliable and affordable electricity for PJM ratepayers.
The PJM BOM should reject the 2022 Window 3 solution and look to find ways with the State of Virginia to build generation within the data center development areas. In addition, PJM should also find ways to protect the operation of our reliable, dispatchable generators until other technology has the capability to take its place.
Sincerely,
Patti Hankins Maryland Ratepayer 

The PJM TEAC’s project recommendation to solve 2022 Window 3 issues does a disservice to all of PJM’s 65 million ratepayers and you should not approve it.

PJM’s plan is unlikely to be completed and will result in higher electric rates
PJM does not have a backup plan for the possibility that one or more segments of its plan cannot be built. Upon questioning, PJM staff said it would leave that problem on the doorstep of the designated entities. When certain segments are not approved, it makes other segments unnecessary. PJM staff is behaving like a Pollyanna, refusing to acknowledge the certainty that its plan cannot be fully constructed as proposed. This could lead to abandoned projects and increased rates for consumers, who will be forced to pay for project segments that never connect and are never built.
PJM staff has not shared any backup plan to maintain reliability and/or serve new load in the event that the recommended projects are not built by the targeted in-service dates. As more baseload generation retires prematurely but is not replaced with equivalent new generation, PJM is pushed closer and closer to grid failure. PJM would not be realistic, or even erring on the side of caution, to ensure continued reliability by relying solely on a massive new transmission build out that has an unlikely chance of success.
In addition, PJM staff’s assignment of hard to site greenfield projects to non-incumbents will only delay and complicate approvals. It is likely these projects cannot be built at all, and certainly not by entities unfamiliar with the impacted communities and state regulators involved. Like any transmission project on new easements, greenfield projects have a very low chance of approval and an almost certain chance of creating entrenched community and political opposition that leads to delay and abandonment.
The recommended plan is indisputably PJM’s biggest transmission endeavor to date. PJM’s recent track record of getting big projects approved and built is shockingly poor. Beginning with the PATH and MAPP project cancellations in 2012, several other large PJM projects have since been rejected and abandoned. There was the Monmouth County Reliability Project, rejected by the NJ BPU in 2018. There was the Transource Independence Energy Connection, rejected by the PA PUC in 2021. Community and political opposition drove all of these cancellations.
The shedding of over 11,000 MW of baseload generation combined with more than 7,500 MW of new data center load is a serious threat to not only the reliability of the grid, but to the pocketbooks of the 65 million consumers who depend on it. It’s the biggest threat PJM has ever faced. Such an enormous problem deserves a new approach. The new data centers in Northern Virginia provide benefit to some of the richest companies in the world, such as Amazon, Google and Facebook. The closing of baseload generators stems from the energy policies of certain states. But yet the entire region is being asked to fund a solution to this grid emergency created by the powerful few. It is unjust and unreasonable to place the costs and the impacts on portions of the region that will not benefit. If current planning and cost allocation rules require this travesty, then it’s time to change them because they have become unjust and unreasonable.
The Law of the Instrument is a cognitive bias that is often expressed with the phrase, "If the only tool you have is a hammer, every problem looks like a nail.” PJM’s transmission planning epitomizes the Law of the Instrument because it prioritizes transmission as the only possible solution. The PJM Market Monitor has been recommending for the past 10 years that PJM create “...a mechanism to permit a direct comparison, or competition, between transmission and generation alternatives, including which alternative is less costly and who bears the risks associated with each alternative.” (2023 Quarterly State of the Market Report for PJM: January through September, Pg. 719). PJM does not allow the market to work to drive the building of new generation in areas experiencing increased load or generation retirements. If PJM had adopted the Market Monitor’s recommendation in 2013, PJM wouldn’t be planning more than $5B worth of transmission as the only solution to solve generation retirements and data center load. PJM must now develop the recommended mechanism in order to allow for beneficial competition between transmission and generation to solve 2022 Window 3. The Board of Managers should reject the TEAC recommendation and order a new evaluation that compares new generation near load with new transmission to other states in the region in order to find the least cost, least impactful, solution for PJM’s ratepayers.

PJM’s Plan is Destructive to Clean Energy and Environmental Justice Progress
While governments and consumers are asking for cleaner power generation, PJM’s plan doubles down on fossil fuels by importing excess electricity from West Virginia and Pennsylvania. West Virginia and Pennsylvania still produce the majority of their electricity from coal and natural gas. Instead of cleaning up the environment in PJM states, increased dependence on fossil fuels actually increases pollution and regional haze. It makes no sense to close coal-fired plants in Maryland like Brandon Shores and Wagner, only to replace their supply with electricity from coal-fired plants in West Virginia. It’s just as dirty, except it’s in someone else’s back yard and requires $5B of new transmission that consumers will have to pay for.
By building new transmission to old coal plants, PJM ignores the questionable longevity of these existing generators under the EPA’s Clean Power Plan, or other state or federal clean energy legislation. The generators may retire before the new transmission line to the west is completed; creating a stranded asset that is not useful to the ratepayers who continue to pay for it. Certainly the expected life of the coal-fired generators is much shorter than the 40-year life of new transmission. New transmission to old power stations on the verge of retirement makes no sense.
PJM’s plan takes a huge step backwards for environmental justice and equity. While wealthy counties in the Washington, D.C. suburbs would increase their economic development, jobs and prosperity with new energy hog data centers, struggling communities in West Virginia face increased pollution from mining and burning coal to produce additional electricity to serve those data centers. West Virginians would also sacrifice their homes and working land to make way for new transmission lines to serve the data centers. As the final insult, West Virginia’s consumers would have to pay for PJM’s new transmission plan that hurts their own communities while benefitting politically connected communities elsewhere.
There has to be a better solution. This plan should be sent back to the TEAC with recommendations to develop a different plan that relies on new generation sources closer to load and produces less burden on communities that will not benefit, and therefore stands a much better chance of being approved and built in time to maintain reliability and serve new customers.
Any new transmission that cannot be constructed fully in existing rights-of-way must be buried within existing road, rail or other public rights-of-way. PJM must consider the use of buried HVDC along existing transportation corridors to transmit electricity from substations in the west, such as 502 Junction, to new substations in Loudoun County’s Data Center Alley. HVDC transmits more power with less line loss in situations where electricity is transmitted long distances without serving load along the way. Buried HVDC on existing rights-of-way reduces project risk from community opposition, delay, or cancellation. While buried HVDC may be more expensive up front, it produces considerable savings. Buried HVDC on existing easements does not require new land acquisition. It avoids public relations and state regulatory battles fueled by community opposition. Time is money and a project that can be built on time and on budget because there is no opposition creates an enormous savings. After buried HVDC is constructed on existing road and rail easements, it does not require perpetual vegetation management, and it is not subject to weather-related damage or sabotage. Outages are less frequent than with overhead transmission and the cost of just one outage caused by overhead line vulnerabilities can easily exceed the increased costs of constructing buried HVDC. Many transmission developers have found that the savings produced by buried HVDC obviates its higher up front cost.

PJM’s TEAC Process
PJM’s Transmission Expansion Advisory Committee has engaged in what I believe to be a deliberate campaign to misrepresent new transmission routes, while simultaneously attempting to thwart participation by non-member stakeholders. PJM’s maps of proposed projects continually misrepresented new greenfield transmission line proposals as brownfield. Maps were also inaccurate and did not match the written route narratives submitted by the proposing entities. PJM went through so many revisions to its maps that I have lost count. Is PJM’s mapping staff really that incompetent, or was the map debacle just a ruse to draw attention to the maps, instead of substantive comment?  I tried to discuss the issue of new easements adjacent to existing transmission lines at length with PJM staff because they insisted these new developments are “brownfield” developments. Brownfield developments are those that are entirely contained on existing easements. Anything that requires new easements, in whole or in part, is greenfield development. Adding additional transmission to existing corridors can actually be more destructive than greenfield routes in areas without existing transmission. The reason for this is that new communities have been built up along the edges of transmission easements that have existed for a number of years, even decades. The existing easements are hemmed in on both sides by new homes, schools, fire stations, churches, businesses, parks, and other developments. Creating a new transmission corridor on a new easement directly adjacent to the existing corridor will require the destruction of the existing community. This is not brownfield development. In contrast, a new line on a greenfield easement can be carefully sited to avoid homes, schools, fire stations, churches, parks and businesses. Brownfield can be, and often is, more destructive to host communities than greenfield.
After my provision of a written example of destructive brownfield siting (along with aerial photo), PJM staff said that they would be creating a new category for the maps to differentiate greenfield next to existing lines from brownfield. This appeared in one set of maps, but has since been eliminated, with PJM reverting back to painting all its new corridors as “brownfield or next to existing ROW.” Who is PJM trying to fool with this misrepresentation? Is it the communities who will host new lines? Or is it the Board of Managers, who may approve new transmission projects without full knowledge of the destruction they may cause to impacted communities because they have been incorrectly informed that the majority of the projects are brownfield? PJM staff is making an incorrect presumption that expanding existing corridors with new easements is preferable to greenfield lines, a view that is not shared by host communities. Since all opposition stems from community impact, PJM’s incorrect presumption does not serve to lessen opposition. It only serves to misinform the Board of Managers.
At the August TEAC meeting, I asked how impacted communities could share vital information about new or expanded easements that could be incorporated into the constructability reports to inform determination of risk. I was told that the public could comment verbally during PJM’s monthly TEAC meetings, a process that is not user friendly. Many people had difficulty signing up for TEAC meetings, and even when they managed to crack that nut, they were faced with sitting through many hours of the meeting waiting for an opportunity to comment, as the discussion of these new projects was always the last item on the agenda. I asked that PJM accept written comment from the public instead. PJM staff either did not answer my emails, or took weeks to do so. By the time PJM staff finally agreed to accept written comments, they told me we needed to hurry up and submit comments because the contractor was finalizing its constructability report. PJM staff managed to delay long enough to prevent all but the most determined commenters from weighing in. This is not an open and inclusive stakeholder process. In fact, it thwarts stakeholder participation.
Once the constructability studies were completed, PJM staff refused to share them, preferring to share only a table with risk determinations, and not the considerations that went into them. It appears that even that table has been manipulated to change the results presented from meeting to meeting, with risk determinations changing without notice or explanation. I believe that the constructability studies are just as manipulated as the rest of PJM’s process and urge the Board of Managers to review them carefully. PJM has recommended some of the riskiest projects for the Board’s approval. Someone needs to ask them why.

Local impacts
The West project in Jefferson County, WV was presented as a preferred solution submitted by NextEra Energy Transmission to wreck and rebuild an existing 138kV line underneath a new 500kV transmission project. As proposed, this project would expand the existing easement and construct new, larger lattice towers. It was stated that this project would deviate from the existing 138kV easement in certain areas and create a completely new easement for the new 500kV line. This proposal was never accurately represented on PJM’s maps, which characterized the entire project in Jefferson County as brownfield. At the Oct. 31 TEAC, PJM staff reassigned the project to FirstEnergy, without explanation. We in Jefferson County cannot determine how FirstEnergy will approach it, how much existing easements must be expanded, or where new easements are expected to go. FirstEnergy has been awarded a project it can create in the future to suit its needs, not one that has been properly evaluated and shared with the public.
The existing FirstEnergy 138kV transmission line running across Jefferson County from west to east has been in place for decades. In some areas, it parallels an existing 500kV line owned by Dominion that was rebuilt, completely within the existing easement, around 2012. Since the original construction of the lines on this combined right-of-way decades ago, new development has been built bordering it, limiting the ability to expand without causing considerable destruction of the built community. The landowners along the easement don’t consider this easement expansion and addition of larger structures to be brownfield development.
FirstEnergy’s Transmission Rights-of-Way Restrictions prohibit the following items in its easements: buildings, lighting fixtures, signs, billboards, swimming pools, decks, flag posts, sheds, barns, garages, playgrounds, fences or other structures. As well, septic systems, leach beds, and/ or wells are not permitted within a FirstEnergy transmission right-of-way. Expanded easements will undoubtedly run into these structures on adjoining property, requiring their removal. Depending on the size of the lot, it may not be possible to move or reconstruct them on the remainder. Expanding the existing easement will cause considerable damage to host properties.
Several new utility-scale solar generation facilities have been approved adjacent to the existing easement, along with an interconnection to the 138kV line. Some of these facilities are currently being developed, with panels constructed directly adjacent to the existing easement. Depending on the expansion of the easement, many brand new panels may have to be removed. In addition, the existing 138kV line will have to be taken out of service for extended periods of time to allow for the demolition and rebuild. When asked how these generators would be able to transmit the energy they produce while the transmission project is offline, PJM staff did not have an answer.
During its Oct. 3 TEAC, PJM staff indicated that they had failed to recommend certain proposed projects due to historic opposition to a previous transmission project in the same area (TrAILCo). However, PJM’s consideration of historic opposition was not applied equally to other areas that have successfully opposed new transmission in the past. Jefferson County formed vehement and entrenched opposition to the PATH project between 2008-2012. That opposition was a factor in the PATH’s project’s ultimate cancellation by PJM. The proposed PATH project used the exact same route through Jefferson County that is now being recommended for PJM’s new 500-kV project. A dozen years is not long enough for impacted communities to forget what happened last time. The only difference between the TrAILCo opposition in Virginia in 2007 and the PATH opposition in West Virginia in 2010 is the deep pockets and political connections of the opposing community. Is PJM afraid of engaging important, well-funded opposition in one state, and instead preferring to engage less politically connected and funded opposition in another? This is the epitome of environmental injustice, where disadvantaged communities are expected to accept damaging new infrastructure over and over again.
The proposed 500-kV project in Jefferson County is not on a direct route to the data centers in Northern Virginia that need a new power supply. Instead it is an unnecessary and destructive diversion that seems to capitalize on an existing transmission line crossing of the Appalachian Trail near the Virginia border. If not for that existing crossing, a more direct route for this project could be utilized. Jefferson County is being sacrificed to prevent a new crossing over the Trail even being proposed. Perhaps PJM believes that it will attract less opposition by destroying Jefferson County than it would for designated entities to ask the National Park Service to permit a less costly and less invasive new crossing further south. We in Jefferson County object to having this project cross our county at all.

​Conclusion
I ask that PJM’s Board of Managers short-circuit PJM staff’s double-time march toward approval of these new projects on December 11 and allow additional time for meaningful public consultation and comment carried out through a user-friendly process. In addition, I ask that PJM present true and correct information about these projects, and their intended routes and risks, to both the public and the Board of Managers before approval. Please do not approve the recommended 2022 Window 3 projects on December 11.

Constructability?  Is that a word?  My internet spelling police hates it, but constructability is defined as:

PJM loves its constructability analyses to select a project from a pool of many options.  PJM pretends it's all so scientific and dependable.  But, is it really?

Here's PJM's Constructability and Financial Analysis Report.  I didn't expect it to be anywhere near correct or accurate, and I wasn't disappointed.  It's completely illogical to the point of demonstrating bias.  Why is it that PJM has selected some of the most risky projects to recommend for approval by its Board of Managers?  Here's what I mean (see page 115 of the report for larger image):

Out of this "west" group, PJM has selected the riskiest project, Proposal 853.  853 has two "high" risks, two "medium-high" risks, and two "medium" risks.  It's the riskiest one in the table.  So, maybe it's about costs?  Proposal 853 costs $1,195,240.  It's still more than the cost of Proposal 904 at $1,122,400.  It can't be based on price.  Just what DID motivate PJM to select 853 instead of 904 or one of the other projects on the table?

What is proposal 904?  It's the building of a new 765kV transmission line through a section of central Virginia.  904 connects the data centers to a huge inventory of fossil fuel generators in the Ohio River Valley using AEP's 765kV transmission network.   Significantly, proposal 904 keeps all the transmission necessary to serve Virginia's new data center build in Virginia.  The other proposals inflict the burden of serving Virginia's data centers on other surrounding states.  Keep that in mind as we examine these two competing proposals as PJM did in its Constructability report.

Project 853

Project 853 has medium-high constructability risks, while 904 has medium constructability risks.  Gee, no help there either.  904 is cheaper and less risky, but PJM still selected 853.

And then there's this tidbit... did you catch it the first time you read it?  

PJM KNOWS this project isn't going to happen the way it was proposed and recommended for approval.  PJM is already anticipating so much opposition to the new greenfield segment in Loudoun County that it will have to abandon this plan and move the proposed new 500kV transmission line over to an existing corridor between Doubs and Goose Creek.  What is that corridor?

The 853 project in Loudoun is represented by that green line.  The Doubs corridor is represented by that roughly parallel yellow line to the east.  Sounds like a solution, you think?  Think again!  PJM has also recommending work on the Doubs-Goose Creek corridor to add another 500kV line to its existing 500kV and 230kV lines.  In order to squeeze another 500kV line in there, PJM proposes to rebuild the existing 230kV line as a double circuit 230/500 kV line, and then add a second 500kV line.  Moving the 853 project over to the Doubs corridor would add a THIRD 500kV line to that existing corridor.  Would that be a double circuit 500/500 kV, in addition to a 230/500 kV double circuit?  Or would there be one 230/500 kV double circuit, and two separate 500 kV lines?  Either way, it will require significant expansion of the current easement through a heavily developed area of Frederick and Montgomery Counties (Maryland) and construct an unimaginable amount of power in that corridor (three 500kV circuits + one 230kV circuit).  Chances of success on this idea rate right up there with the survival of a snowball in Hell.  Which area is capable of forming bigger opposition?  Loudoun County or Frederick/Montgomery Counties?  Personally, I think it's a tie.  Either one is going to kill this project dead.  Remember, it's not about fighting each other to push the project off onto someone else, it's about stopping the bad project altogether.  Nobody wants this anywhere!

So, what did we learn from PJM's constructability analysis?  Not much.  PJM did not examine the gray areas of opposition that I did.  PJM pretty much ignored the possibility of opposition derailing their plans.  Dismissed!

But, we're not going away.  In fact, we're only going to get stronger.  I predict that this project will NEVER get built.  Maybe PJM should go back to the drawing board and take another look at project 904?  Why did they dismiss that project anyhow?  PJM never actually says.  In fact, after reading all of PJM's excuses, err I mean analyses, I came away more convinced than ever that this whole thing is a farce.  Some of the excuses for not selecting a project were so ridiculous, such as -- we didn't select this project because we selected a different project.  That's not a REASON for making a project selection.  I also got the idea that PJM is absolutely terrified of rich people opposition in certain areas of Northern Virginia.  PJM has bowed down to the wealthy and privileged due to their bad experience trying to route the TrAIL project through those areas.  PJM thinks it's a better idea to route its projects through disadvantaged areas that can't fight back (or so they think).  That kind of thinking is outrageous in this day and age of environmental and energy justice reform.  Add in the fact that PJM's new transmission lines are nothing but extension cords importing dirty, delicious, coal-fired electricity out of West Virginia and Pennsylvania and you've got a project idea that is dead on arrival when asking for federal help.

Stupid, stupid, stupid, on top of dumb, dumb, dumb, PJM!  It's obvious PJM has another agenda at work here and it's not providing needed electric service at the lowest cost.  Let's hope the PJM Board of Managers examines this farce carefully before making its decision on December 11.