Last month, I told you about a proposal that was submitted to PJM Interconnection that would turn MARL into a double-circuit 500kV transmission line between the Fort Martin power station in Morgantown, WV and the new Woodside substation in Frederick County, VA.

Well, PJM has finally posted its new maps and there's one that shows what this NextEra proposal would look like, if you had trouble following along with the narrative I gave you last time.

​Here it is:  

This map shows a second 500kV circuit beginning at the Fort Martin power station.  A double circuit is just what it sounds like... two 500kV circuits on a common structure.  It is unlikely that the two circuits will be stacked vertically on the structure.  More likely that they will be separated horizontally, with one 500kV circuit on a horizontal arm on each side of the structure.  This is going to change the look of the towers, perhaps their height, and perhaps their width.  It also doubles the amount of power MARL can carry.

The double circuit structures will end at Gore, VA, where NextEra's segment of the project ends.  Because FirstEnergy owns the eastern segment of MARL that continues on from there, NextEra will have to put its second 500kV circuit on new structures on a new 200 ft. wide right of way.  This is an enlargement of the Frederick County section.

You would still get Gore-Doubs-Goose Creek 500kV on new poles on one side of the existing easement, plus you would get MARL 500kV #2 on a new 200 ft. right of way on the north side of the existing easement.  And don't forget Valley Link, which will add another 200 ft. to all that for its own line of 765kV towers.  Impacted landowners would have not only 1,765kV of electricity added to their properties, but an additional 400 feet of right of way as well.

Meanwhile, at the other end of MARL #2, NextEra proposes to add a new 500kV substation at the point where existing lines feeding from Ft. Martin intersect with MARL #1.  That part of PJM's map doesn't look exactly accurate, so here's my attempt at mapping where the new Sandy Creek substation may be located north of Bruceton Mills.

Of course, this is going to delay MARL significantly because they're going to have to go back to the drawing board designing the structures.  They're going to have to have new Open House meetings to show you their updated project, too.  And this project is likely to include parts that are ultimately assigned to FirstEnergy, such as expanding the Fort Martin substation.  If FirstEnergy is assigned components of MARL #2, then FirstEnergy would have to start from square one on its part of the project.  The new 500kV NextEra line in Frederick County would also have to start from scratch and hold Open House meetings before filing an application.

So, what happens next?  PJM will be evaluating this proposal (and 133 others around the region) and discussing them at upcoming meetings with the goal of choosing projects by the end of the year.  It's unlikely NextEra will move forward with its application until it knows whether it will be approved to add that second 500kV circuit.

When your friendly, neighborhood land shark... err agent, land agent, shows up to pressure you about signing an easement agreement, perhaps you should be asking him about NextEra's MARL double circuit proposal?  There's more you're not being told...

​This week, both NextEra and Potomac Edison made filings at the West Virginia Public Service Commission indicating that they intend to file applications for their respective segments of a new 150-mile 500kV electric transmission line.  The line moves coal-fired electricity from a substation in Greene County, Pennsylvania to a substation in Loudoun County’s “data center alley.”  Data center alley is home to the largest concentration of data centers in the world.  Regional grid operator PJM Interconnection planned the project, and assigned a different segment to each company to complete.
 
NextEra Energy has responsibility for the 105-mile segment from Pennsylvania to a point in Frederick County, Virginia.  NextEra named their segment MARL.  The new transmission line continues with a 45-mile segment from Frederick County, Virginia to Loudoun County, Virginia that is assigned to FirstEnergy, Potomac Edison’s parent company.  Potomac Edison named their segment Gore-Doubs-Goose Creek, after the substations it connects.
 
Each company is responsible for securing a state utility commission permit in every state which its project crosses.  A Notice of Intent to file an application is required by West Virginia law to be filed at least 30 days before the actual application, and expires after 90 days.
 
The West Virginia Public Service Commission has opened a permitting docket for each company’s application.
 
The Case Number for Potomac Edison’s segment is NOIE Potomac Edison 25C.

The Case Number for NextEra’s segment is NOIE NextEra Energy 25A.
 
The new dockets enable concerned persons to formally file comments and/or petitions about the projects at the PSC.  To do so, visit the PSC’s website and select “Submit a Comment” from the left hand menu.  Then select “Formal Case” from the next screen.  Agree to the disclaimer on the next page, and it will bring up a form to fill out with a space to type your comment.  Be sure to include the Case Number in your filing.
 
If you would rather mail your comments in, send them to:
 
West Virginia Public Service Commission
201 Brooks Street
Charleston, WV  25301
 
Be sure to write the Case Number on your comments.
 
If you previously submitted comments, Resolutions, or letters to the PSC about these projects, you may need to resend them with the correct case number on them in order to have them become part of the official record in the docket.  You may file comments on either, or both, docket(s).  There is no limit on how many comments you can send.  You could send them one every morning over coffee until a decision is made.  It’s up to you.
 
Next Steps: 
 
The companies will file their applications in their respective dockets.  Once the application is filed, the company must notify impacted landowners by certified mail at least 30 days before the deadline to intervene in the case.  The PSC will set a deadline to intervene in the case after the application is filed.  It may be as soon as 30 days after the application is filed, but not sooner than the company sends you a notice via certified mail.
 
Intervening means becoming a legal party to the case, with the right to file testimony and cross-examine the company’s witnesses.  Intervenors may also file briefs, recommending a decision to the PSC, and only intervenors have a right to appeal the PSC’s decision in the case.
 
Persons with an interest in the case, whether as an impacted landowner or electric ratepayer, may intervene and request party status.   Intervenors may hire an attorney, or they may participate pro se, which means representing himself or herself without an attorney.  Intervenors may also join together and hire one attorney to represent an organized group of intervenors, which can make representation less costly.  We will have more information about intervening coming up soon.

The companies assigned to build one of the components of PJM Interconnection's project B3800 have made an absolute mess of the public's understanding of the project.  Congratulations, NextEra and FirstEnergy!  This is all your fault!

PJM doesn't invent and assign cutsie-poo names like MARL or Gore-Doubs-Goose Creek to the projects it approves and orders.  It gives them numbers.  B3800 was assigned to this project when it was approved in December 2023.  Names like MARL and Gore-Doubs-Goose Creek are inventions of the companies that PJM assigns to build the projects it orders.  Different names do NOT mean different PJM projects.  They're all B3800.

Here's the only thing you need to know about MARL and Gore-Doubs-Goose Creek.

A picture is worth a thousand words, right?  If you study this one, you'll figure it out, despite the stupid stuff NextEra and FirstEnergy are saying right now.  Block all their nonsense out of your mind.  This is one continuous 500kV transmission line.  It's all connected, just like a gigantic extension cord.  Pay attention to the key on this map.  There is a table called  "Transmission System Enhancement" that lists the different color-coded line segments and the companies that PJM assigned to build each segment of this ONE 500kV line. 

Starting at the top of the list is a dark pink/purply segment assigned to AEP.  AEP stands for American Electric Power, who owns a section of existing 500kV line between the Kammer substation and the 502 Junction substation.  AEP's part of this project was to study its existing line to assure it could pump more power from Kammer.  Kammer is the name of the substation at AEP's Mitchell Power Generation station in Marshall County, WV.  AEP is not building a new line here (at least not in this project).

Next the table lists yellow for Dom.  That stands for Dominion.  Dominion is the Virginia-based utility that will be building the last 3 miles of this 500kV circuit from Edwards Ferry to Goose Creek in Loudoun County, Virginia.  It's really impossible to see the yellow part of this map because it's tiny compared to the rest of the line's mileage.  Just know it's there, at the eastern end of the line.

Then we have red for Exelon.  Exelon owns a short segment of existing line and easement in Montgomery County, Maryland that would be reconfigured to change a corridor containing one 500kV line and two 230kV lines into a corridor that contains three 500kV lines and two 230kV lines.  One of those new 500kV lines in Maryland is part of B3800, the continuous 500kV line from 502 Junction to Goose Creek. You can barely see the red if you look hard.

And now we're getting to the real meat here... blue and peach.  The blue part of the line is owned by FirstEnergy (FE) subsidiary Potomac Edison.  The FE part of the line begins at a point in Frederick County, Virginia where the NextEra part ends and runs east through Jefferson County, WV, Loudoun County, VA, and Frederick and Montgomery Counties, MD to a point at Edwards Ferry where Dominion picks up the construction of the 500kV circuit.  The blue part of the line is approximately 45 miles long.  The blue part of the line plans to tear down an existing 138kV circuit on 65 ft. tall towers and replace it with double circuit 500/138kV lines on a new tower 185 ft. tall.  FirstEnergy named this part Gore-Doubs-Goose Creek.

And last, but certainly not least, the peachy colored part of the line that is assigned to NextEra.  This 105-mile long segment begins at 502 Junction substation and ends at a point in Frederick County, Virginia were FirstEnergy's segment of the project begins.  We're literally talking about two adjacent transmission towers carrying one continuous 500kV circuit, except one tower is owned by NextEra, and the other is owned by FirstEnergy.  These are not two separate projects physically.  The separation only exists in legal documents and the balance sheets of competitors NextEra and FirstEnergy.  NextEra named its peach MARL.

To put the parts of the map in order from west to east:  dark pink (AEP), peach (NextEra), blue (FirstEnergy), red (Exelon), more blue (FirstEnergy), and then yellow (Dominion), which connects to a substation that serves Loudoun County's data centers.

PJM approved and ordered ONE 500kV circuit between 502 Junction and Goose Creek and then assigned the project to 3 different companies to build.  Each company has made up its own name for its segment.  NextEra calls its 105-mile portion of the project MARL.  FirstEnergy calls its 45-mile portion of the project Gore-Doubs-Goose Creek.  Dominion has not come up with a name for its 3 mile section in Virginia because it has not presented the project to the public yet.

This confusion about who owns what and what the project is called and what connects to what can be flung directly on the door step of NextEra and FirstEnergy.

NextEra has been playing pretend games that its 105-mile segment of PJM's 500kV circuit is a separate project not connected to anything else.  NextEra says it begins in PA and ends in Frederick County, Virginia.  The media has added the narrative that MARL connects with "a data center in Frederick County, Virginia" which is just false.  There are no significant data centers in Frederick County.  All the data centers are in Loudoun County.  Loudoun and Frederick are not even contiguous counties.  Jefferson County, WV sits between them.  We need some basic geography here!

NextEra may have created this false narrative in the press because it thought that it could escape any bad data center juju being attached to its project.  Didn't work.  We all know MARL is a data center extension cord.  All that narrative did was confuse the heck out of people when Jefferson County popped into the picture on Monday when FirstEnergy filed a Notice of Intent at the PSC.

FirstEnergy, for its part, contributed to this confusion by refusing to name its project, or to do any public relations about it until just recently (and still its attempts can be called anemic at best).  The citizens of Jefferson County have been fighting FirstEnergy's part of PJM's 500kV circuit for 2 years now.  Because FirstEnergy refused to acknowledge the project, we named it for them, and we called it MARL, adopting NextEra's name for this 150-mile long 500kV circuit.

So, when FirstEnergy's Potomac Edison filed its Notice of Intent at the PSC, it said the project was "also referred to as MARL".  That is absolutely 100% true.

And the media circus began.  The stories pumped out don't even make sense, and the confusion becomes deeper and deeper.  Take a deep breath... just look at the map!

I'm guessing that NextEra got its corporate panties in a wad yesterday because FirstEnergy had used their MARL name in their Notice of Intent at the PSC. FirstEnergy tried to issue a retraction yesterday.  This confused things even more.

And, using my best mom voice, here's some advice that NextEra and FirstEnergy should take to heart.

GET OVER YOURSELF, KIDS!

Stop your bickering and squabbling and not wanting to be associated with each other.  It's going to come back and bite you in the butt at the PSC.

The PSC will have two separate applications for two different segments of the same transmission line.  Are the companies going to keep pretending they have nothing to do with each other before the PSC?  That's going to be a little uncomfortable for PJM's witness, won't it?  You'll never get away with it.  And it would serve you right if the PSC denied one of these segments because they didn't know the other was connected to it.

​FIX THIS MESS!

PJM Interconnection, our regional grid operator and planner, is always planning something.  PJM regularly presents problem statements to transmission developers and solicits proposed solutions as part of a competitive transmission process.  Each RFP for transmission solutions is called a "window".  PJM presents its problem statement, and willing developers submit proposed solutions.  PJM's competitive transmission windows are what brought us the MARL, Gore-Doubs-Goose Creek, and Valley Link projects.

Once the open "window" closes, developers submissions are posted on PJM's website with a lot of "competitive" information redacted so that only a skeleton of the proposal is available to the public.  These bare bones proposals are turned into maps and tables that PJM's Transmission Expansion Advisory Committee (TEAC) discusses at its monthly meetings with the goal of selecting one of more of the proposals to address the problem PJM described.  The discussion and selection usually takes place over the course of several months, and once PJM's TEAC has selected a project or projects, it must read them into the record twice at committee meetings before submitting them to PJM's Board of Managers for approval.  If PJM's Board of Managers approves the new projects, they are added to PJM's Regional Transmission Expansion Plan (RTEP) and assigned to their transmission developer sponsors.  PJM signs what's called a Designated Entity Agreement (DEA) with the developer and the developer begins routing and engineering studies and eventual public information sessions that they call "Open House" meetings.  This is the exact process that MARL, GDGC and Valley Link have followed.

PJM opened a new competitive window in June of this year to solve a number of problems with the transmission system.  The main problem, as always, is that Northern Virginia demand is skyrocketing due to new data center proposals.  You can look at the factors PJM was considering by reviewing PJM's TEAC meeting slides from last month.  PJM said that some of the lines bringing power from the west would be overloaded in 2032.  Here's one of their maps.

I will share that PJM's meetings and information are high on the techno-speak level and may appear confusing to most people.

PJM's 2025 Window 1 closed on August 18.  PJM received many new transmission proposals.  Not all proposals submitted will ultimately be selected.  However, we have a first look at what has been proposed so that we can follow PJM's evaluation of these proposals and selection of the projects it wants to move forward.  Here's the full list of proposed projects (expand the 2025 RTEP Window 1 link).  They are simply referred to by number, and each number has a brief description of the project, with much of the specific information redacted to protect competitive information.  The name of the proposer is always redacted, however there's much we can garner out of the information that is not redacted that gives us clues about who may have proposed them.

One of the proposed projects is numbered 896.  This proposal, which may have been made by FirstEnergy or NextEra, calls for turning MARL into a double circuit 500kV transmission line, and adding a second 500kV line to the first segment of GDGC across Frederick County, Virginia.

The proposed MARL double circuit begins at FirstEnergy's Fort Martin power station in Morgantown, WV.

The project calls for a new 138kV line from Ft. Martin to a new substation in Mon County that would be called Sandy Creek.  The proposed Sandy Creek substation will intersect with MARL and feed power directly from Ft. Martin to the new 500kV circuit proposed to be added to the MARL project.  The Sandy Creek substation is described:

The new 500kV circuit will be added to MARL's proposed towers so that MARL would consist of TWO 500kV transmission lines, possibly hanging from the same new tower.  The proposer says this doesn't make any difference because MARL has not been constructed yet so they can change the towers and the circuits.

This includes the entire portion of MARL from a point in Mon County to the place in Frederick County, Virginia where the MARL project ends and the Gore-Doubs-Goose Creek project begins.  It would impact Mon, Preston, Garrett, Allegany, Mineral and Hampshire Counties.  The proposer says it will use "existing right-of-way" but that right-of-way doesn't actually exist yet and will only exist if MARL is approved and built.  It only exists on paper right now because NextEra has not actually obtained any right-of-way for the MARL project in those counties yet.  Talk about counting your chickens before they hatch, right?

Once this new double circuit 500kV line gets to the demarcation point between MARL and GDGC in Frederick County, Virginia, it proposes to run on a new 200 foot right of way for 17 miles across Frederick County until it reaches the proposed Woodside substation owned by NextEra.

They can't simply continue the double circuit on the same new towers when they get to Frederick County because that is the point where the Gore-Doubs-Goose Creek line is already planned to be constructed as a double circuit with the existing 138kV line.  The second 500kV circuit would need a whole new right-of-way parallel to the existing configuration.  And don't forget that Valley Link is coming along behind it and creating its own new 200 ft. right-of-way.  Frederick County is looking at not only the new 185 ft. tower for the first 500kV circuit, but the addition of two new lines on parallel rights-of-way that would add 400 feet to the existing 250 foot wide corridor.  Total if this is selected and completed:  650 feet wide right-of-way with three 500 kV lines, one 138kV line, and one 765kV line.  That's a whole lot of power and a whole lot of expansion for Frederick County!

Meanwhile, back in Mon County, Fort Martin's substation must expand for this plan.

The new line from Fort Martin to the new Sandy Creek substation will be constructed for approximately 1-mile and parallels the Hazelton to Lake Lynn 138 kV in Mon County on a proposed new 100 ft. right-of-way.  A second new 138kV line from a nearby substation will also parallel Hazelton to Lake Lynn for an additional 2 miles of new 100 ft. right-of-way.  That's three miles of new right of way in Mon County, and a new substation.

Seems like double jeopardy for impacted landowners, doesn't it?  As if it's not bad enough that MARL is proposed for your property, now the transmission companies want to double your pain with a second 500kV circuit and miles of new right-of-way, and a new substation, in Mon County and Frederick County.

For what?  To get power to data centers in Northern Virginia.

It really emphasizes the fact that these new transmission lines are NOT for West Virginia, and they are NOT needed to attract new data centers in the West Virginia counties they cross.  They are for Northern Virginia data centers, they are not for us!

PJM's TEAC meetings are open to all "stakeholders".  We are all stakeholders in this and anyone may attend the TEAC meetings where these projects are discussed to ask questions or make comments.  PJM TEAC meetings are held once a month, during the work day, and may be attended via Webex or over the telephone.  If you want to attend, you can sign up on PJM's website.  You must have a PJM account and pre-register for the meetings.  If that's not your cup of tea, you can simply get updates from citizens who regularly attend these meetings and save your written comments for PJM's Board of Managers if this proposal is ultimately selected by PJM's TEAC.

Remember, this is only a proposal right now and there is no guarantee it will be selected.  However, MARL and Valley Link were once only just proposals like this, so consider this a heads up on what PJM may be cooking up to invade your community in the future.

Transmission extension cords from West Virginia will never be enough for Virginia's insatiable appetite for electricity and it is expected that PJM's planners will keep adding more and more unless West Virginia stands up and says NO.  

West Virginia's talk news has been all over the subject of the MidAtlantic Resiliency Link, or MARL, for the past couple of weeks.  Despite their heroic efforts, they've barely scratched the surface of the truth about MARL.  It's much more complicated than can be explained on a brief radio show, obviously, and probably more than can be covered in a brief facebook post.  Isn't it time for everyone to dig a little deeper?  I promise it won't be too complicated.  I've learned to distill understandable facts from of the energy industry's big jug o' technospeak over the past 17 years.  This won't hurt a bit!

I'm going to concentrate on a recent MetroNews Talkline radio interview of NextEra's Kaitlyn McCormick.  Listening to it was pretty rough because Kaitlyn kept fading in and out and it was hard to understand much of what she said.  Was she talking on a cell phone while driving through West Virginia's beautiful mountains?  Or was she just waving her phone around while trying to talk on speaker?  Take your pick.  I'm going to use the equally bad transcript to try to decipher exactly what she said.

Let's begin with the fact that MARL is only one part of a larger project approved by PJM Interconnection.  Even Kaitlyn admits that, although the radio hosts insist on treating it like an individual project.  This is a map of the project PJM approved:

MARL is the light peachy-colored line here that begins at the 502 Junction substation in Greene County, PA and ends just over the state border at Gore, VA.  The blue line is a continuation of the new 500kV line to be built by rival company FirstEnergy.  They are calling their project "Gore-Doubs-Goose Creek" after the substations it will connect.  FirstEnergy's portion of the project begins where NextEra's ends and heads east to continue the electricity extension cord to its ultimate destination, a substation in Loudoun County's "data center alley" called Goose Creek.  Neither one of these projects can stand alone.  PJM needs BOTH of them to be built to deliver this power to a whole bunch of new data centers planned in Loudoun County.  MARL is not delivering power to a data center in Frederick County, Virginia.  It is simply plugging into FirstEnergy's portion of the project in Gore.  If one of these two line segments isn't built, the other one won't be built either.  It's all or nothing because PJM needs both segments to deliver the power from 502 Junction to Goose Creek.

And let's talk about 502 Junction for a moment, shall we?  502 Junction is an existing substation located in Greene County, PA.  Think of 502 Junction as the Grand Central Station of electricity.  It collects electricity generated by plants in the area and re-directs it to new destinations.  Just because 502 Junction is located in Pennsylvania doesn't mean that all the electricity that passes through there is generated in Pennsylvania though.  In fact, most of the electricity passing through 502 Junction is generated in West Virginia!  Here's a map of PJM's transmission system showing 502 Junction and the lines that connect there. 

This map shows what generators connect to 502 Junction to deliver their electricity for re-direction elsewhere.  To the west is AEP's Mitchell plant.  Connecting from the south is FirstEnergy's Harrison plant.  In Morgantown, lines connect both the Longview and Ft. Martin power generators to 502 Junction.  On its way to the southeast, this project will connect with lines feeding out of Dominion's Mt. Storm power station in Grant County, WV.  That's over 7,000MW of hot, juicy, 100% West Virginia coal-fired electricity, and Virginia's green virtue signaling data center companies are hungry, hungry, hungry for it!

And they're hungry because Virginia has closed down many of its fossil fuel generators that can run when called in favor of intermittent solar and wind projects.  Virginia has closed more generation than they have brought online, creating a power deficit.  In addition, Northern Virginia is practically exploding with new data centers proposed by some of the wealthiest companies on the planet (Amazon, Google, Microsoft, Meta).  Virginia has no way to power all the stuff it's building.  Virginia just keeps demanding that PJM import more and more power to Virginia, and PJM has only one place to get it... West Virginia!

And this leads us back to WHY PJM Interconnection ordered this project.  PJM did NOT select the two end points for this project.  PJM only selected one, Goose Creek, where the data center load is located.  PJM was open to any transmission extension cords bringing up to 7,500MW of new electric supply from anywhere, as long as it connected to Goose Creek.  It was NextEra who decided that there was an opportunity to suck up to 7,500MW of coal-fired electricity out of West Virginia.  Here's a PJM slide that verifies this need, as well as what the need is for.

PJM needed new transmission to address reliability problems that would develop on its system if it connected 7,500MW of new data center load in Northern Virginia.  If the only tool you have is a hammer, every problem looks like a nail.  While PJM's job is to keep the lights on by making sure power flows throughout the region when needed, PJM's only tool to get the job done is transmission.  PJM cannot order new generation to be built, and Virginia is taking advantage of that.  Virginia considers itself a "clean" state and passed a "Clean Economy Act" that relies on importing more and more coal-fired power from West Virginia.  It's okay for Virginia to pollute our state, but not their own.  West Virginia is just their dirty little energy colony.  It's time to stand up and say enough is enough!

MARL is located in West Virginia simply because West Virginia is in the way of the extension cord from 502 Junction to Loudoun's data center alley.  There's no way to get West Virginia generated electricity to those Virginia data centers without destroying West Virginia along the way.  NextEra doesn't care about that.  They're going to make billions!  Virginia doesn't care about that.  They're also going to make billions in new tax revenue if they can build new data centers powered by West Virginia coal imported via gigantic transmission extension cords.

Kaitlyn made much of MARL connecting to an existing substation at the Mineral/Allegeny border.  That substation is called Black Oak.  It's been there for decades.  MARL needs to connect there for what PJM calls "voltage support."  When transmission lines are long and don't connect anywhere along their path (such as a line from 502 Junction to Goose Creek) they can get unstable and need injection of reactive power along the way to maintain the correct voltage.  MARL is connecting with Black Oak to suck power out of that substation in order to stabilize its voltage, not to deliver power to either county.  PJM has stated that there will be no new substations planned along MARL's route.  MARL isn't for West Virginia, or any community along the way.  MARL's entire capacity is already called for by data centers in Loudoun County, VA.  There is no way for West Virginia to benefit from additional substations.  That's not how new demand is planned.  

In order to plan to build new load in any location, there has to be an actual customer who requests electric service.  No utility (or PJM) plans to build power lines or generators with the hope that doing so would attract new load.  All utility infrastructure must be used and useful to the consumers who pay for it.  So, a real data center must request electric service in your county.  Then the utility that serves your county must evaluate whether they can serve the load with the existing system.  If so, the new load is connected.  If not, then the utility sends a load request up to PJM, who includes that in their next transmission planning load forecast.  This is exactly how MARL was planned.  It wasn't planned for us, it was planned for data centers in Virginia.

Kaitlyn's blathering about congestion and reliability in West Virginia avoids the real issue... connecting more data center load in Virginia is what destabilizes the system because Virginia is not also connecting more electric generation to match its load request.  There are only congestion and reliability issues in West Virginia if those data centers in Virginia are connected.  If West Virginia doesn't approve MARL, then those data centers will have to wait longer to be connected, or will simply go elsewhere that has available power.  PJM will not connect new data centers that will cause blackouts on the system.  PJM's first job is to maintain the reliability of the existing system.

Kaitlyn tries to pull a fast one on these radio hosts and listeners.  She says that everyone's goal is to minimize overall impacts.  This presumes that everyone agrees that MARL must be built.  West Virginians do NOT agree it needs to be built, or that MARL is a fait accompli.  West Virginians believe that this project is not logical or helpful to West Virginia and that it can be stopped!

Kaitlyn prattles on about paralleling existing transmission lines as a least impactful solution.  That's only if you don't live near those existing lines.  Where's the equity in property impacts between those properties already doing their part to host unwanted public infrastructure and the rest of us who don't have to do anything to help?  Paralleling existing transmission lines is actually MORE impactful because it cannot deviate around homes or other land uses like a line sited on unburdened land.  Paralleling is only "better" in the minds of transmission executives and PJM planners who think landowners who live next to existing easements will be a push over.  How about now?  How about one of the biggest waves of transmission opposition in PJM history?  Is paralleling still such a great idea?  It's not.  It's an idea that needs to die.

MARL will cost West Virginians hundreds of millions of dollars.  Kaitlyn really needs to find out how those rates are set.  This is the second time she's told a lie about the state utility commissions setting rates for MARL.  Even after she was invited to her own company's annual formula rate update meeting! Maybe she's just playing dumb so she can lie with a straight face?  Transmission rates are set by the Federal Energy Regulatory Commission.  State utility commissions have no jurisdiction to set those rates and must pass them through to their state consumers unscathed.  Kaitlyn needs to stop making me think she's dumb as a box of rocks and perhaps get some training about transmission cost allocation and rates.

The only way we're going to get to the bottom of this is to keep digging!

For years, West Virginia has been the target of big green lawsuits, and the butt of arrogantly rude jokes.  Our state has mined coal, burned coal, and exported the electricity produced for more than 100 years.  West Virginia is one of only two consistent electric power exporters in our PJM Interconnection grid region.  States to our east, however, have adopted their own "clean energy" legislation that causes fossil fuel electric generation within their borders to close, such as the Virginia Clean Economy Act.  However, these "clean" states have no qualms about importing increasing amounts of dirty coal-fired electricity from West Virginia though.  Virginia's plan to supply its "clean" economy with electricity relies on increased imports of electricity from West Virginia.

Virginia's economy has created "data center alley," the largest concentration of data centers in the world.  The whole world!  And Virginia has been powering them with our dirty coal-fired power from West Virginia.  This is what has made Loudoun County, Virginia, the wealthiest county in the nation.  The whole nation!

And there Virginia sits, sneering at West Virginia and making jokes about how we're at the bottom of many state achievement lists and maligning us as a bunch of hillbillies who actually LIKE being trodden by Virginia's polished boots on our neck.  If there's something the "civilized" in Northern Virginia want that comes with impacts, they look right away to West Virginia as their sacrifice zone.

Today's West Virginia is DONE with that!

Now Virginia wants to build out a network of AI data centers, the largest in the world.  But Virginia also doesn't want to have the infrastructure necessary to power those data centers in their own back yard.  Virginians would yell and scream about the protection of their environment, while demanding that the infrastructure they don't want be moved to West Virginia.

Instead of building the infrastructure to power the data centers Virginia wants near the load they are creating, Virginia is playing a coy game with regional grid operator PJM Interconnection.  They simply encourage new AI data centers to make load requests to Virginia public utility Dominion Energy.  Dominion sends these impossible load forecasts up to PJM Interconnection, and PJM uses the only tool at its disposal to meet the load request of a public utility... transmission!  PJM does not and cannot order the construction of new generation.  It can only plan and order transmission, and that's exactly what it's done... planned and ordered new transmission extension cords from West Virginia's coal-fired power plants to serve the new AI data centers in Virginia.  West Virginia's public utilities, owned by corporations based in Ohio, are thrilled with this arrangement because they not only make money selling more electricity produced in West Virginia, they also rake in billions of dollars building new transmission extension cords.

This has to STOP!

AI data centers can be built practically anywhere that there is power and water available.  They don't need to be located within Northern Virginia's data center alley.  AI data centers could actually be built in West Virginia, in communities that want them and their tax revenue.  That's exactly what West Virginia's elected officials were thinking this year when they passed The Power Generation and Consumption Act (aka HB 2014).  However, it seems that data companies are hardly beating a path to our door.  Instead, there was a big announcement recently where Pennsylvania became the home to many new data centers in the planning stage. 

Apparently it takes *more* than just allowing data centers to build their own generation.  And it's all about who pays!  West Virginia's Power Generation and Consumption Act makes the data center pay to build its own power.  Other states simply push the service requests up to PJM interconnection, who orders new transmission that electric consumers pay for.  West Virginia is also a vertically integrated state where utilities own generation, transmission and distribution.  Generation built by our utilities is paid for by West Virginians.  When data centers get built in other states, West Virginians end up footing the bill to power them!  Frankly, that is OUTRAGEOUS!

After all these years, West Virginia finally has something other states want.  West Virginia needs to quit giving it away and being satisfied with the crumbs left from the other state feasts.

Take back your power, West Virginia!  Don't allow new transmission extension cords that drain our power to be built in West Virginia!  West Virginia has the final say whether new transmission extension cords are built in West Virginia.  If West Virginia keeps allowing other states to siphon off our power, there's nothing here to attract data centers.  They'll locate in surrounding states and suck all our power out of West Virginia.

Say NO to new transmission extension cords providing OUR power to surrounding parasitic states!  If we keep feeding new data centers in Virginia, they never have any reason to build here instead.   Keep our power here, providing economic development to our own state.

Take back your power, West Virginia! Say NO to new transmission extension cords across our beautiful state!

Yesterday, landowners in Virginia began receiving letters from FirstEnergy's transmission group with information about the first of several transmission extension cords ordered by regional grid operator PJM Interconnection to power Loudoun County's data centers with West Virginia generated coal-fired electricity.  The letters also invited landowners to several "Open House" meetings to be held along the project route in mid-August.

Tuesday, August 12, 2025
6:00-8:00 P.M.
Lovettsville, VA
Lovettsville Volunteer Fire Hall
12837 Berlin Turnpike
Lovettsville, VA 20180

Wednesday, August 13, 2025
6:00-8:00 P.M.
Shepherdstown, WV
Shepherd University Wellness Center
164 University Drive
Shepherdstown, WV 25443
​
Thursday, August 14, 2025
6:00-8:00 P.M.
Winchester, VA
Museum of the Shenandoah Valley
901 Amherst Street
​Winchester, VA 22601

If you didn't get a letter (yet), you can read the letter by downloading this file.  Sorry, but FirstEnergy is withholding access to its website until August 12.  Be sure to mark that down to include in your comments to the Public Service Commission... withholding of information and insufficient time to meaningfully interact with the community during routing.

You are encouraged to attend these Open House meetings to get more information and to ask questions, lots of questions.  Feel free to attend any (or ALL) of the meetings, but the meetings will be identical.  So, if you forget to ask a question, or need more information, hit repeat the next night at a new location.

The Open House meetings for transmission projects are always the same format, and I've been to lots of them.  It's NOT a "Town Hall" or other form of meeting with a formal information presentation with designated speakers followed by a Q&A for everyone at the meeting to take turns asking questions.  Instead, these meetings are a place for individuals to hunt for little bits of information at certain "stations" set up around the room.  Bring your Sherlock Holmes outfit, not a prepared speech.  It's pure divide and conquer.  Each station will cover a specific topic and be staffed by one or more FirstEnergy subject matter "experts".  You are supposed to enter the room and sign in to give FirstEnergy all your contact information so that their land agents have an easier time harassing you in the future.  Then you are supposed to filter through and interact with each station set up along the perimeter of the room like cattle in a chute.  When you finally get to the end of the stations (back where you began) you will be asked to fill out a comment card and let FirstEnergy know what you think about the project.  This is a diagram of their set up:

There is no place for you to make a public comment to all the meeting attendees, so don't bother writing one.  Instead, you will talk one-on-one with FirstEnergy employees and contractors.  If you insist on having a moment and making a shouted announcement to all the attendees inside, count on FirstEnergy to have security at the meeting who will escort you out.

Open House meetings are loud and confusing.  There are hundreds of people talking at once in a confined space.  It is extremely hard to hear what anyone is saying, even someone right next to you.

Sometimes, the companies go all out and provide food, drink and freebie souveniers, such as keychains, notebooks, or cheap Chinese Yeti knockoffs with their project name on them.  FirstEnergy ain't having none of that at the Maryland meetings for Gore-Doubs-Goose Creek (aka MARL).  There will be nothing for you except paper handouts.  Not even a drink of water.  Bring your own so you can stay hydrated.  It's been hot out there!

And speaking of hot out there... feel free to stage a protest outside the Open House meeting.  Wave signs, sing songs, chant, but don't block the entrance or waylay people on their way inside.  They'll probably be back to join you after getting their own dose of "information" from inside.  Get to know other people in your community who are also affected by the transmission project.  Exchange contact information.  Create a petition against the project for people to sign.  But remember, keep it peaceful and don't interfere with what FirstEnergy is doing inside.  Sorry I won't see you there, but we can talk afterwards.

Here are some photos from FirstEnergy's June Open House in Montgomery County, Maryland.  

Need more inspiration?  Here's what I just filed.

Comments of Keryn Newman
Docket No. AD25-7

“Breaking the internet” is a figurative phrase coined to describe an overwhelming surge in web traffic that impedes the operation of the World Wide Web. In an ironic twist, the internet is now breaking us, or more precisely our grid. The generators, transmission lines and distribution systems that make electricity available to everyone can no longer function in the same way they have for decades because they have been overwhelmed by new service requests from artificial intelligence data centers.

This enormous surge in electricity demand is breaking energy transition goals, bedrock regulatory principles, how we plan the energy system, and PJM’s capacity market, just to name a few. It is also breaking consumers ability to pay for the electricity they need. Soon it could even impede their ability to receive service at all as the amount of electric generation continues to shrink and the amount of electricity required by artificial intelligence skyrockets. We are sacrificing our real, human world for an artificial one that exists inside machines.

Our entire energy system and the way we regulate it needs to be torn down and rebuilt to efficiently and cost effectively serve today’s reality. Of course, that cannot happen. We no longer have the luxury of time. Elected officials and regulators have ignored the clear warning signs that were present for a number of years in favor of indulging in politicized industry fantasy. The fantasy is over. It’s now reality.

At FERC’s Resource Adequacy Technical Conference, Commissioner Christie asked whether states should require load-serving entities to acquire enough generation to cover their load forecasts in advance, requiring that they build or buy sufficient generation to meet load. That ought to be the first condition to be a member of a resource sharing organization such as PJM Interconnection, but it is not. PJM states such as Virginia are raking in the cash and benefits created by new data centers and leaning on other states to supply the power they need to enable those new data centers. As Commissioner Christie pointed out during the technical conference, when everybody leans on everybody else, everybody eventually falls down.

Importing more electricity from a neighboring state to serve increased demand is not smart energy policy. It’s a house of cards that cannot stand. PJM has become a group of “haves” and “have nots.” PJM’s State Import-Export Map shows a real time picture of which states are importing electricity, and which states are exporting it. West Virginia and Pennsylvania are consistent electricity exporters. Virginia, Maryland, Washington DC, Delaware and New Jersey are consistent energy importers. It is no longer an equitable sharing of resources among states. There are states that have energy, and states that have not. There are states that are givers, and states that are takers. Where’s the value of PJM membership for the states that are consistent exporters and perpetual givers? There is no value when one state is consistently taken advantage of over and over again. West Virginia has been treated as the east coast’s sacrifice zone, exploited by corporations to benefit wealthier states and treated like a dump that becomes the butt of rude jokes. But, perhaps artificial intelligence is also breaking West Virginia’s victimhood. This year West Virginia approved a new law called the Power Generation and Consumption Act, which allows companies seeking to build data centers in the state to create their own, independent energy grids to power them. West Virginia is getting into the data center game, trying to lure the industry here where energy is plentiful and data centers can bring their own generation and be part of the solution, not just the problem. It makes so much more economic and engineering sense to bring the load to the power than to try to bring the power to the load. West Virginia has found a way to accommodate data centers that does not create financial burden on other ratepayers, or land use burdens on private property.

Over the past several years, PJM Interconnection has planned and ordered more than $11B worth of new baseload transmission to import more and more electricity to Northern Virginia’s “data center alley” from West Virginia and Pennsylvania. These new transmission lines do not provide benefit to West Virginia and Pennsylvania. They are nothing more than gigantic extension cords for the purpose of exporting resources to “have not” taker states, mainly Virginia.

The resource adequacy crisis needs an immediate solution. Satisfying new data center demand can be done three different ways. The fastest and cheapest way is to restrict new data centers to locations with onsite or nearby available power. The second would be to build new generation near data center load, but that takes more time to permit and build and the price is steep. The last, most time consuming and expensive option would be to build transmission extension cords from existing generation to new data centers in other localities. Instead of selecting the fastest and cheapest option for the grid, PJM and the Commission have opted to rely on the slowest and most expensive way to power new data centers, building new transmission. This is not a viable solution and will take much too long to implement because new transmission is never a sure thing.

The impacts of Virginia’s skyrocketing data center load will be devastating to West Virginia, which is primarily bearing the brunt of the Commission’s broken regulatory system that no longer assists consumers in obtaining reliable, safe, secure, and economically efficient energy services at a reasonable cost through appropriate regulatory and market means, and collaborative efforts. West Virginians will pay more than $440M to construct and operate two new transmission extension cords for Virginia's data centers. The MidAtlantic Resiliency Link is a new 160-mile 500kV line that will take a new 200-foot wide right-of-way through private property. Valley Link is a new 261-mile 765kV transmission line that will take an additional 200 ft. wide right-of-way through private property. In Hampshire and Jefferson Counties, West Virginia, these two separate transmission lines will converge to create a transmission superhighway as wide as two football fields laid end to end. Hundreds of homes may be taken and demolished to make way for Virginia’s insatiable appetite for new data centers. There are no benefits for West Virginia, just impacts. Membership in PJM and the Commission’s transmission planning and cost allocation procedures no longer work to provide benefit to West Virginians. We’re being used to benefit other states.

The Commission has been constantly tinkering with interconnection queues, markets and other forms of regulation but has yet to find a solution to the growing problem of resource adequacy. There seems to be little the Commission can do in the face of rapidly increasing load from data centers. All its tools no longer work. What the system needs is more generation near data center load. Because Virginia refuses to build it, other states are being torn apart for new extension cords and consumers are quickly being priced out of being able to afford basic electric service. The system is broken.

Data centers are not just another electricity customer who must be accommodated using existing rules that share burden among all customers. The Commission should take a page from West Virginia’s book and require data centers to bring their own power to wherever they choose to locate, or locate where they may directly connect with generators with excess capacity. Those localities that will not allow data centers to build their own generation cannot continue to lean on the system to support their own economic development. It’s parasitic. Once data centers are separated from the host they have been feeding on and become self-reliant, the resiliency problem solves itself. We simply don’t have any more time to wait while the Commission slow rolls minor fixes here and there and hopes for results.

Stand up for West Virginia!  It's not going to change until you do!

YOU get a substation!  Everyone gets a substation!

Has NextEra promised you a substation?  Has another transmission company that wants to run a transmission line through your county or district offered you a substation?  Does your county actually NEED a new substation, or is it being promised as a speculative draw for new data centers or industry in your county?

Talk is cheap.  Reality is expensive.  Really, really expensive.  A new 500kV substation costs around $50M to build.  Even looping MARL (or another new line) through an existing substation in your county costs about $20M.  Who do you think is going to pay for that?  If there's no actual NEED for a new substation, your county or district is going to pay for that.  All of a sudden, it doesn't sound like such a bargain, does it?  After all, your county doesn't have $50M to invest in speculative infrastructure to attract new businesses, does it?

All those promises about NextEra "dropping a substation" in your county or district are likely not only false promises, they are actually ludicrous to anyone who knows anything about how transmission is planned and built.  Don't parade your lack of knowledge around like a blinking beacon.  It's time to look your gift horse in the mouth.  It's just not happening.

Here's the reality about how transmission lines (and substations connected to them) are planned.  In the case of the MARL 500kV transmission project, the NEED came from increased load requests in the Dominion Power zone in Northern Virginia.  Dominion could not serve all the requests it had received to hook up new data center proposals in its service territory.  Dominion's load forecast is made up of actual requests from customers, not speculative requests from politicians or local county planners.  Only electric companies that serve actual customers can add new service requests that become part of the electric company's load forecast at PJM.  If there is no actual customer or NEED for new service, it doesn't go into the load forecast and it doesn't get to PJM. 

Those new service requests at Dominion got added to Dominion's load forecast that was sent to PJM.  In response, PJM opened a new proposal window to serve that need using the transmission system.  MARL was one of the proposals that is purposed to provide 7,500MW of new electricity imports from coal-fired plants in northern West Virginia.  Dominion and its future data center customers are counting on that new extension cord to build.  Those customer requests were made several years ago and cannot be connected until the transmission line is built.  Customers in Northern Virginia can expect to wait up to seven years to get service (if the project is built on time).

If a new data center wants to locate in Hampshire County, West Virginia, it would first make a new service request to the local electricity provider, Potomac Edison.  Potomac Edison would make a determination if it could serve the new customer using the existing system.  If not, Potomac Edison would add the new request to its load forecast that feeds up to PJM for transmission solutions.  However, that new service request would become part of a new planning window, it would not simply "jump the line" to take service away from customers waiting for service in Northern Virginia.

However, if there is no customer in Hampshire, and no new service request for Potomac Edison to serve, Potomac Edison would not add speculative load to its forecast.  The utilities only build the service we actually need.  They don't overbuild their systems based on speculation or political promises.  That's because new transmission and substations are paid for by ALL Potomac Edison customers, and for lines (and substations) 500kV and above, the costs are actually allocated to all consumers in PJM's 13-state region.  Utilities can only charge ratepayers for infrastructure that is used and useful to them.  It cannot charge ratepayers for speculative projects that don't even have a user.

So, where did NextEra's substation promises come from?  Most likely from lobbyists... those sweet talkers who will promise elected officials anything they want to hear in exchange for getting what the company wants.

MARL was originally planned to begin at the 502 Junction substation in Greene Co., Pennsylvania.  It was an unbroken "fly over" transmission line until it reached Frederick County, Virginia, more than 100 miles to the southeast.  There, MARL would build a new 500kV substation to connect MARL with the existing 500kV transmission line called Bismark-Doubs.  That new substation has been named Woodside.  From Woodside, both the existing Bismark-Doubs and the new 500kV MARL line will continue east another 60 miles or so until they connect with an existing 500kV substation in Loudoun County's "data center alley" called Goose Creek.

However, when transmission lines have really long spans between connecting substations, they can lose voltage.  Transmission system owner FirstEnergy noticed that the long span between 502 Junction and Woodside was going to cause unacceptable voltage drop, so they proposed to PJM that the line not simply bypass its existing Black Oak substation as originally planned, but connect there instead on its way east.  According to PJM, the loop into Black Oak is to provide voltage support to the MARL line.  It is NOT to serve new customers in Allegany County, Maryland, as it may have been sold to them in order to gain their support for MARL.  It will actually be taking power from Black Oak, not delivering it.

But, since the Black Oak connection worked so well to snow Allegany County elected officials that they were "getting something" in exchange for hosting the transmission line, perhaps NextEra simply couldn't resist using the same tactic on other elected officials in other impacted communities?  Next thing you know, everyone gets a substation!  And they're just going to "drop" out of the sky, like magic... free magic!  Do these elected officials think that NextEra is paying for all these free, unneeded substations?  Sorry, NextEra has a hard cost cap on the MARL project.  Any freebies they give away are coming out of NextEra's profits.  Also, an unneeded substation is unlikely to be permitted by state regulators.  PJM would have to testify that such a substation is NEEDED and, as as explained above, there is no NEED.  As well, NextEra doesn't serve any end use customers in West Virginia and never will.  Any new service request would be made to Potomac Edison.

In fact, when I asked PJM's planners about the possibility of a substation being "dropped" in Hampshire County (or any other county on MARL's route) I was told that there's currently no plan to do that.  In fact, PJM said that any new customers in those counties would have to make a request to the local electricity provider (Potomac Edison) before anything was planned.  Now go back where we started and read again about how new transmission and substations are planned to serve new customers.

There are currently NO PLANS for new substations to be "dropped" along MARL's route.  Anyone who believes that had best check their facts.  

A new substation is not any more likely than the promises of millions of dollars of new property tax revenue and jobs, jobs, jobs.  It's just not happening.  Oprah can give away cars, but NextEra cannot give away substations.  Don't look like a fool.

Ever feel like the filling in a tuna sandwich?  The "stuff" inside an Oreo?  Well, that's exactly what you are if you're on the Jefferson County section of PJM's 502 Junction to Goose Creek transmission project.  We're being sandwiched between NextEra's MARL on the western side, and FirstEnergy's Gore-Doubs-Goose Creek project on the eastern side.  We're the one remaining area without any maps or information.  Apparently we're being saved for last because we're the ones FirstEnergy is most worried about.  We're the ones who are supposed to remain compliant and in the dark because FirstEnergy has not given us any notice.  Well, wake up folks, this is your notice!

FirstEnergy has finally emerged from their bat cave to disseminate public information about the eastern half of the project.  As I told you several weeks ago, FirstEnergy is calling the eastern half of MARL the melodious Gore-Doubs-Goose Creek project.  You can continue to call it MARL if you like.  It doesn't matter what you call it, as long as you don't call it late for the financial incentives buffet (haw, haw, haw).

But, FirstEnergy is only willing to share information about the Maryland part of its project, and says it wants to file an application with the Maryland PSC by the end of the year.

Despite PJM's empty promises about "using existing rights of way" for eastern MARL, FirstEnergy is planning to expand existing easements and acquire more property.

Fact sheet?  What fact sheet?  Maybe it's on their website?  What website?  The only information you're going to get is going to be in person at the ONE and ONLY "Open House" FirstEnergy is holding for this project.

A public information session on the project is scheduled for June 11 from 6 to 8 p.m. at the Upper Montgomery County Volunteer Fire Department in Beallsville.

This is your only chance to get information.  Be there.

Meanwhile FirstEnergy continues to slink around, approaching landowners with predatory proposals before giving them complete information about the project.

Don't just sit there.  Do something!