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Don't Be A Stan

6/19/2018

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This is Stan Whiteford.  He's a communications professional with Public Service Co. of Oklahoma.  He's been doing that job for a long, long time.  And then Wind Catcher happened.  Stan wasn't prepared.  Stan is stale, boring, and uses canned talking points.  Stan's on camera persona is awful.  Stan seems surprised to be the most hated man in Bixby.  Stan can't handle this job.  It's time for Stan to retire.  Don't be a Stan.

Yesterday, Stan said:
PSO spokesman Stan Whiteford said the company is continuing to reach out to people in Bixby and surrounding areas on “study routes.”

“The council already indicated they are opposed, but we just want to make sure we have the opportunity to talk to all the people in Bixby so they have a chance to understand that 7,000 PSO customers in Bixby stand to benefit directly from reduced rates and also that Bixby schools will benefit with several million dollars from (property) taxes related to the project,” he said.

“We recognize certain landowners have concerns and we are trying to address those with them and will continue to respond to any and all questions and inquiries about the line route,” he said.

Whiteford said PSO will continue to reach out to residents, rate payers and government officials.

And he also stated:
"We understand infrastructure development is often controversial and while many landowners welcome the payments they'll receive, and on-going benefits to schools and the community, others have equally valid personal reasons for opposing development. However, this project is important for PSO customers and for our state. Customers, especially those who create jobs in the areas we serve, increasingly expect renewable energy and we have an obligation to deliver it at the lowest reasonable cost. We're extremely disappointed that the City took this action since we've worked closely with Bixby for many years on economic and community development and have always held them in high regard. In the meantime, we will continue to reach out to people in Bixby and surrounding area, work to address landowner concerns and respond to any and all questions about the line route."
So what happened last night at the Bixby City Council meeting when Stan had his opportunity to "reach out" to the hundreds of people gathered on the Wind Catcher issue?
Stan was at the Bixby City Council meeting tonight. He was given the opportunity to address the council and citizens. He declined. He was asked for an interview but requested to go outside. He stood and gave his interview, under the guard of (our wonderful!!!) Bixby PD officer. He would not make eye contact. He would not smile, acknowledge, or address ANY of these landowners and people they want to “hear and respect”.
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And then what happened?
He is escorted back into the building and once he believes everyone is gone, he sneaks out the back door!!!! Successfully avoiding ANY conversation.
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Stan doesn't walk his talk.  His claims of "reaching out" to concerned residents are nothing but a performance for the media.  Nobody believes Stan anymore.  His credibility is less than zero.

And you know what's weird?  The jocular act Stan launches into when talking about all the supposed "benefits" of Wind Catcher.  It's really not funny to anyone but Stan and whatever idiot wrote "smile beneficently while talking about tax revenue" in Stan's script needs to tone it down.  Stan only looks creepy when he does that.  Really creepy!

There are no benefits for the landowners affected by Wind Catcher's transmission line.  "Investment in the state" is something no landowner cares about.  And perhaps Stan doesn't realize that part of the reason Oklahoma is so "desperate" for revenue to support schools is because of wind tax credits handed over to out of state wind developers.  So why should Oklahoma build even more wind turbines?  Claims of Wind Catcher being "pro-business" because Oklahoma has low electric rates and it will attract businesses to the state are also just something nobody seems to care about... even the businessmen of Bixby that PSO invited to a private meeting where they were fed a card stacked, cherry picked, cheer squad performance for Wind Catcher.  Word is they decided to remain neutral.

The whole tax revenues thing is a scam transmission companies use to try to lure local governments into selling out their citizens and taking the utility blood money.  Looks like Bixby isn't falling for it.  Maybe Stan should jettison that talking point.  It's falling on deaf ears. 

And let's talk about misinformation, because Stan thinks that now that he's losing, and losing badly, that it's because of "misinformation."  Stan wants you to focus on facts and real issues... like $300M of additional tax revenue for the state.  That's not an issue.  The issue is the lack of need for the project, and the millions of dollars it will cost PSO customers in higher electric rates.  All Stan's claims of lower electric rates have been examined by the OCC and found not credible.  In fact, the judge recommended that the Commission deny the application.

Stan is misinformed if he thinks the problem with Bixby is an information deficit.  The problem for Stan is that the residents of Bixby know the truth about the project and they refuse to be victimized.  No matter how much Stan tries to "communicate the benefits" of the project to Bixby, there's no going back from staunch opposition.  How many people will change their mind and begin to support the project once Stan tells them about all the "benefits?"  Exactly none, that's how many.

And speaking of fictional characters...

Stan says:
... although a few opponents have raised objections, the vast majority of Oklahomans support Wind Catcher,” he said.
and
... while many landowners welcome the payments they'll receive, and on-going benefits to schools and the community...
No one has actually seen or heard any of these landowners.  I think they all live in the woods with Bigfoot and are quite elusive.  Or maybe Stan is simply making them up in a weak attempt at bandwagon.

Stan is really not very good at his job.  He's allowed the Bixby problem to turn into a raging inferno.  Perhaps Stan and PSO/AEP thought they were so close to the finish line that they didn't have to pay attention to the new opposition that was developing.  Perhaps they thought they could stuff the genie back in the bottle with a couple of meetings for businessmen and the chamber of commerce, maybe sprinkle a few "donations" around, pretend they "respect" landowners, and wave around some tax revenue.  It didn't work.  It never works.  And now AEP has a huge problem with Bixby that's going to affect what happens at the Oklahoma Corporation Commission.  Last night, Bixby voted to hire an attorney to take action to ask the OCC to dismiss the Wind Catcher application.  And whoopsie, Stan, the Associated Press picked it up, resulting in headlines like this around the country: 

Oklahoma residents, city against $4.5B wind power line route

Stan is continually owned by the Wind Catcher opposition in the media.  Watch as Stan is pitted against fresh, engaging, and real opponents in news stories and ends up looking like a shyster.

Wind Catcher project gets blowback from some Bixby residents.

Bixby City Council joins fight against PSO Wind Catcher project.

Stan has completely failed on Wind Catcher.  Don't be a Stan.
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AEP is Desperate for Wind Catcher Approval in Oklahoma

6/13/2018

1 Comment

 
What was it AEP's CEO said about the time line for the company's Wind Catcher project recently?
Nicholas K. Akins - American Electric Power Co., Inc.
I don't think there's a statutory deadline, but certainly there's a business deadline. I mean, we've been very transparent about the timing necessary and the procedural schedules have been set up consistent with getting a decision on time. So, I think it's really more driven by, I guess, one of the previous questions sort of brought out, when is our drop-dead date and that kind of thing. But I can just tell you that May and June fits.
May and June.  AEP must have its Wind Catcher project approved in May and June.  Of course, May and June were an extension of AEP's original time line to  have Wind Catcher approved by April.
Steve Fleishman - Wolfe Research LLC
So just if I recall back last fall, you had talked about wanting decisions by April to make sure that you would have it online to get the full PTCs.  Is May-June going to be okay to be able to capture full PTCs? Like, what is the real deadline?
Nicholas K. Akins - American Electric Power Co., Inc.
Yeah, we'll be fine. Really, we have to get to a point of getting these orders in place, and then we'll cover it with our board, obviously, in our July meeting. And then once they approve it, we're off and running. So if we get it in that June timeframe, we get the orders in the May to June timeframe, we'll be in good shape.
And here it is mid-June and the Oklahoma Corporation Commission (OCC) has yet to make a ruling.  It sort of seems like they've been waiting for a settlement to happen so they didn't have to make a decision at all.  However AEP has failed at reaching a settlement with all parties, and the parties who oppose have proposed their own settlement.  And what about the Administrative Law Judge?  Didn't she hear this case months ago and issue a Report and Recommendation that AEP's application be denied?  What about that?

Will AEP push its approval deadline ahead, or is this really it?  How fast can Invenergy build a wind farm, and how fast can Quanta build a transmission line?  And would either one of these two AEP contractors want to invest serious money buying components without a guarantee that AEP will reimburse them in the event the project is cancelled?

I'm going to guess this is AEP's last desperate push to get its project approved.... because its recent filing at the OCC has desperation written all over it.

Here's what AEP has asked the OCC to do:
  1. Supplement or re-open an alternate "record" of Commission deliberations on Wind Catcher.  This record is separate from the evidentiary record considered by the ALJ when she recommended denial.  That record cannot be re-opened.  It sort of looks like AEP is asking that the Commissioners completely ignore the recommendation of its Administrative Law Judge.
  2. Allow AEP to present its "settlement agreements" with some of the other parties as "evidence."  None of these agreements are unanimous and none of the settling parties represent the interests of the PSO ratepayers who will be saddled with the cost burden of Wind Catcher in their monthly bills.
  3. Use AEP's settlement agreements as "the basis for a final order."  In other words, AEP is asking the OCC to approve a contested settlement based on some new evidentiary record comprised of AEP's settlement agreements and supporting "testimony."
  4. Issue an Order setting a hearing on the merits to consider AEP's settlement agreements and new "evidence" before the Commission en banc commencing on the 2nd day of July 2018, at 1:30p.m., and continuing each business day thereafter until the hearing concludes, in Courtroom 301, Third Floor, Jim Thorpe Office Building, 210 I N. Lincoln Blvd., Oklahoma City, Oklahoma 73105.  AEP even included a sample order that the commissioners simply have to sign, easy peasy.
The fly in AEP's ointment is that the Commission has yet to issue the requested order.  The Commission has not yet filed a response to AEP's motion.  The hearing is not yet set.

But, I wonder, if AEP can re-open some alternate evidentiary record on a whim, whether the affected public can also contribute to this new record by giving public comment during the proposed hearing?  I suppose anyone can ask by filing a motion similar to AEP's.  Being a regulatory attorney is no big thing... even a monkey can do it.  And it sort of looks like a monkey DID do it for AEP.... because the legal basis for AEP's proposed course of action for Wind Catcher doesn't really give it legs.  AEP's monkey is simply throwing stuff against the wall and hoping something sticks. 

Because AEP is desperate.  Desperate to get Wind Catcher approved before its own impossible deadline.
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It remains to be seen what, if any, response the OCC will make to AEP's desperate machinations in this election year.  I'm pretty sure AEP cannot cast a corporate vote for PSC Commissioners, nor can it force its employees to cast certain votes as a condition of their employment (although apparently it can force the employees to sign letters of support to the OCC).  Who will be electing the OCC Commissioners?  The people of Oklahoma!  The same people who may have their properties devalued and spoiled by a new transmission line.  The same people whose electric bills will go up to pay for AEP's Wind Catcher folly.  I'm sure the OCC Commissioners will choose very carefully... while you watch.

UPDATE:  The Oklahoma Attorney General and Public Utility Division of the OCC have also filed a motion docketed this morning asking the Commissioners to consider their joint statement against preapproval and proposed settlement agreement in the event that the Commissioners decide to approve Wind Catcher despite all the evidence that this project is not beneficial to ratepayers.

And the best part?  They have asked for the OCC to re-open public comment and made it easy on you.  That's some pretty wishful thinking ;-)  Or maybe it was just common sense...
PUD and the Attorney General additionally respectfully request that public comment
by members of the public interested in the outcome of this proceeding be allowed at
any hearing to take evidence on the PSO Settlement and the Consumer Protection
Settlement Agreement.
It's a perfectly reasonable request.  If AEP wants to create a new evidentiary record, then the record should be open to everyone.  If ordered by the Commissioners, this means that anyone and everyone will be permitted to speak directly and in person to the Commissioners during any new hearing that is set and let them know what you think.  So, mark your calendars, landowners and keep your eye on the OCC docket to see when and where (or if) a hearing is ordered by the Commissioners.  AEP failed at public notice of its plan and the vast majority of landowners were not aware of Wind Catcher's effect on their properties during the first OCC hearing.  If you feel you weren't heard, this could be your golden opportunity!  Don't miss your chance!
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U.S. DOE Wastes Your Money on Another Stupid Idea

6/8/2018

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Analysts report that consumers served by utilities on the nation's East and West coasts pay higher costs for their electricity than we do here.
News flash!  That's because "here" (the Midwest) doesn't have a network of expensive, gigantic transmission lines to pay for.

Think about it.

DOE obviously hasn't.

DOE is stuck in 2009, when the idea to lower coastal power prices by building a "national grid" was novel.  Now that idea can only be called FAILED.

So, the DOE has a big new idea for "the installation of a network of high-voltage, direct-current transmission lines could boost the availability of reliable, affordable power generated by renewable sources at load centers on the East and West coasts."

Hey, Einstein, building your ginormous dream grid costs money.  Lots and lots and lots of money.  We're talking billions.  And your plan expects that electric customers nationwide will finance that investment over decades to come and pay its private investors/owners double-digit interest throughout its lifetime.  No thanks, we simply can't afford it.

Don't you think that adding additional costs to move energy thousands of miles will only increase energy prices, both on the coasts and the Midwest?  Building new transmission to reduce costs on one part of the system only produces a leveling of costs across the region.  If prices go down on the coast, they will increase in the Midwest.

And maybe, just maybe, the people who live in the Midwest don't want to live in an ugly, noisy, industrial power plant that only benefits the politically powerful players on the coasts.  And maybe they don't want to live in and work under a network of new high voltage transmission lines.  And they will resist, no maybe about it.  They will shout and block and delay your dream grid for years and years, and that costs even more money.

Don't do it, DOE.  Quit wasting my tax money on stupid things like TransGrid-X 2030.  You already tried this idea once, remember?  You called it Section 1222 of the Energy Policy Act, and you decided to "partner" on an HVDC transmission line from the Oklahoma panhandle to Memphis.  And it failed.  It failed spectacularly.  It couldn't find any customers to purchase capacity.  No income, no project.  So what makes you think, DOE, that a new network of HVDC transmission lines from the Midwest to the coasts would be able to find customers?  You've already done this experiment once and it failed.

I do note that your "symposium" has participation from companies that would benefit financially from building billions of dollars of new transmission.  So you're just acting as a facilitator for private investment here?

Swamp, swampy, swamperson.  Get out of the muck!  Don't you have enough trouble already with your swampy plan to save coal?

The real cutting edge on transmission is to stop building it and develop a secure system of interconnected local microgrids that can be autonomous self-contained systems that continue working seamlessly whether connected to a larger network or not.

Or maybe you can hold a seance and ask Nikola Tesla what he thinks?  That's probably a more productive use of my tax money.

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AEP's Smoke and Mirrors Hide Lack of Regulatory Progress on Wind Catcher

6/4/2018

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AEP announced the addition of several parties to its proposed settlement agreement in Oklahoma last week.  The sycophantic trade press and other outlets duly reported this as regulatory progress.  Lots of smoke and mirrors for something of relatively little value.  It doesn't matter how many minor parties sign up to receive something of value to them when the major party who will pay for the project continues to oppose the settlement.

In the regulatory world, any party with an interest in the proceedings may become a party to the case.  If some of these interests are purely selfish, it doesn't matter.  All sorts of entities intervene in a regulatory proceeding in order to try to score a piece of the pie.  Such was the case in Oklahoma when AEP filed its audacious plan to buy the country's biggest wind farm and build and own the world's biggest "generation tie line."  The project fundamentally changes the nature of wind and other generation projects in Oklahoma and the gen tie line makes other transmission to export renewables obsolete.  So, it's no surprise that a bunch of companies with interests in building generation and transmission in the state intervened in the case.  They intervened because AEP's plan interferes with their own plans.  If AEP builds its project, all these other companies may have to abandon some of their own plans.  But what if they can intervene and negotiate with AEP to preserve some of their own plans and still make money?  Everyone makes money, everyone's happy, right?

Except someone has to pay for all these companies to make their money.  AEP suggests its customers in Oklahoma will pay for its project.  If AEP adds guarantees that the intervening companies will also make money from their own projects, then that only adds to the cost burden for AEP's customers.  And that's exactly what happened last week.

Intervening party Oneta Power received a power purchase agreement for 300MW of gas-fired generation, plus a commitment that AEP will issue an RFP for additional gas generation in the near future.  Now maybe purchasing gas generation would be cheaper for Oklahoma consumers, but this purchase is in addition to, not instead of, AEP's purchase of a wind farm.  It increases consumer costs, not reduces them.  AEP says it was going to purchase this power anyhow, but that plan was originally tanked and replaced by Wind Catcher.  Now all of a sudden, AEP needs both.  If that doesn't smack of buying off a party with someone else's money, I'm not sure what does.  AEP says that this agreement is "in the best interests" of its customers because it allows them to build Wind Catcher.  It has no benefit of its own.

Other recent settling parties received similar goodie bags that also provide no benefit to AEP customers, such as agreements not to infringe upon the retail sales territory of another company, and to allow others the opportunity to build future additions to AEP's transmission system around the wind farm.  None of that saves AEP customers any money.  The customers are still hit with the full cost of the wind farm and transmission line.

And there are plenty more parties who probably want their own piece of the pie before this is done.

It doesn't matter how many pieces of pie AEP serves up to these parties if the parties representing AEP customers don't belly up to the buffet.  The OK Attorney General and Public Utility Division of the Oklahoma Corporation Commission are the only parties to the case who could even remotely be said to represent the interests of AEP customers, and they're not budging.  These parties have made their position quite clear when they filed their own settlement agreement containing terms they believe will protect consumers.  AEP could agree to these conditions and settle the case, then go on to build its project.  However, AEP has refused to do so.  Instead it has gone around serving pie to all the other intervenors with selfish intent.  Perhaps AEP thinks that if it gathers enough parties and generates enough smoke and mirrors that the public will believe they will benefit from the project and that will give the OCC Commissioners enough "cover" to approve the project against the "best interests" of AEP ratepayers in the state.

So why won't AEP agree to the Attorney General's settlement terms?  Because they actually provide protections to AEP's customers who will pay for the project.  AEP says its project will provide benefits to customers, but when the guarantee that it will do so is inked out in black and white on a legal agreement, AEP won't sign it.  This can only mean that AEP's promises of customer benefit are fake.  If providing the promised benefits interferes with AEP's profit, then there is no real benefit and the project should be cancelled or denied.

AEP has asked the Oklahoma Corporation Commission to approve its recovery of costs for Wind Catcher from its customers.  The OCC can do this at any time.  But if the benefits determined by the OCC in any approval don't happen, then the OCC is fully responsible for making a bad decision.  And they must know it would be a bad decision because they haven't done it.

But the project can still be approved without the OCC Commissioners taking responsibility for making a bad decision if a unanimous settlement is presented for approval.  In a settlement, all the parties with an interest in the case have agreed on how to dispose of it through negotiation.  Everyone gets something, and the applicant achieves its goal.  Nobody could blame the OCC since the parties agreed that the settlement was in their own best interests.  It sure seems like the OCC Commissioners are waiting for a settlement so they don't have to take responsibility for making a big mistake.

And AEP is trying mighty hard to come up with a settlement, but not hard enough to stand behind its own promises of customer benefit.  A contested settlement, where one or more parties do not join the majority and continue to oppose, is unlikely in this instance.  Approval of a contested settlement would be categorized as a bad decision that sticks to the OCC Commissioners.  It's all about who the contesting parties are and why they are contesting.  If a minor party, like Clean Line Energy Partners for instance, contested the settlement because AEP refused to buy its failed Plains & Eastern transmission project route, a contested settlement may be reasonable.  However, if the Attorney General  contests in the best interests of ratepayers, that's a whole different animal.  In order to approve that kind of contested settlement, the OCC Commissioners would take it upon themselves to determine the best interests of the ratepayers against the better judgment of the Attorney General, and they would own every bit of fall out when AEP's promised benefits don't materialize.

Pretending that buying support from self-interested parties is progress is nothing more than smoke and mirrors.

And speaking of smoke, be sure not to miss this news story out of Bixby, Oklahoma last week.  Bixby officials asked AEP to make a presentation about its project, and they went, like lambs to the slaughter.  AEP sent its governmental schmoozer, some project rep, and Tim Gaul, its corporate siting guy.  Some of you veteran transmission opponents may recognize that name.  Gaul has shown up as the siting guy on many AEP transmission projects in the past, although he used to work for transmission siting contractor Louis Berger before he went through the transmission revolving door and earned himself a plum position at AEP.  Gaul has been the guy who decided to place a transmission line in your back yard, although public accountability has been rare.  Watch as an unnamed landowner gets in Gaul's face and berates him while pointing a finger.  It gives me the warm fuzzies!  The look on Gaul's face... hahahaha!  Bravo, unnamed landowner, bravo!  You spoke for a lot of people who never had such an opportunity!

At the end of the evening, Bixby officials voted to send written opposition to the project to the OCC.  The people of Bixby have spoken.  There's no purer truth in the transmission business than this...
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AEP Wind Catcher Support Letters to Oklahoma Corporation Commission Signed by AEP Employees

5/29/2018

3 Comments

 
What's a company to do when it wants to create a feeling of overwhelming support for regulatory approval of one of its projects, but it lacks overwhelming support?

Create it with home-grown resources!

Shame on you, AEP!  Your scam wasn't even that hard to figure out.  Which ever one of your "geniuses" came up with passing the tablet in the workplace ought to be fired.

At the very least, the Oklahoma Corporation Commission should be forced to collect and toss any letters of support for the Wind Catcher project that came from AEP/PSO employees and failed to disclose that the author worked for AEP and had a conflict of interest.  That should lighten the docket immensely. 

A little birdie told me that the OCC Commissioners were looking at huge piles of support letters for the Wind Catcher project on their desks.  Perhaps Commissioners were feeling a bit obligated to approve the project's rate scheme because of such overwhelming support.  So, I looked at the OCC docket for the case.  And I found one of the links to collections of public comment on the project.

Funny that... most of the letters were strikingly similar, in fact so similar that they are obviously form letters.  All contain the following  closing paragraph:
For the aforementioned reasons, I sincerely support and endorse Wind Catcher Energy Connection and the benefits that it will bring to Oklahoma. Oklahoma cannot afford to miss out on this opportunity to invest in our state and the citizens of Oklahoma. I would like to thank the Oklahoma Corporation Commission for their thoughtful consideration on this matter.
And they are all obviously signed on an electronic tablet because each individual signature has that telltale "drunken illiterate" look so common to finger signatures on electronic tablets, where the signature box is well defined and limited.

So, who was collecting signatures in support of the project?  Was it some of the usual suspects like Sierra Club?  Well, yes, of course, but an online letter does not create a distinctive tablet signature, and there's no way Sierra Club could draw that many people to a venue in order to sign their tablet.  Sierra Club is no longer a member run organization and has lost its base because it is too focused on scoring grant money anymore.  Who else is running a "send a support letter to the OCC" campaign for Wind Catcher?  Well, Invenergy is.  That's sort of like cheating though, since Invenergy stands to profit enormously if AEP gets its project approved and buys Invenergy's wind farm.  Shame on you, Invenergy!  But even then, how could tablet signatures get generated online?  And why doesn't Invenergy's form letter of support include the telltale concluding paragraph?

Where were these "supporters" gathered?

I tested my first theory that all "supporters" from a certain date may all live in one city and may have attended a single public event where the tablet was passed.  Since the OCC blocked out the addresses of the "supporters" I had to zero in on unique or unusual names to find out what cities the supporters lived in.

And then I found something really interesting.

Kristine Kurszewski.

She supports Wind Catcher.

She's also an Administrative Assistant at Public Service Company of Oklahoma at Bartlesville.

Wow, what a coincidence, right?  Out of all those dozens of support letters docketed at the OCC I just happened to pick one written by an AEP employee.

Except then there was:

Tiney Holyfield, a Project Control Analyst at American Electric Power in Oklahoma City.

Larry Gattenby, an IT Support Technician for AEP.

Levi Grooms, a Project Manager for AEP in Tulsa.

And lots more, but it was starting to get repetitive. 

It looks like all Wind Catcher's "support" letters were signed by AEP/PSO employees across Oklahoma.  What better place to walk around with a tablet and get employees to give you a finger signature?  I wonder if the employees even knew they were signing a support letter to the OCC?  Or did they think they were signing some routine workplace form?  How voluntary were these signatures, anyhow?  Did employees feel pressured to sign the tablet?  I think AEP has a lot of explaining to do to the OCC...

It also needs to fess up to jamming the docket with fake letters of support from its employees.  Once all those fake form letters are gone, the letters of opposition will rise and shine.  They're in there, but buried among the AEP employee form letters so only a very patient person would be able to locate them.

If the OCC Commissioners have piles of support letters on their desks, they need to weed out any written by AEP employees, whose employment may or may not be tied to their willingness to sign AEP's tablet.  Such "support" cannot be seriously considered as reason for approving such a bad project.

Shame on you, AEP!  SHAME ON YOU!!!
3 Comments

Franklin Co. Sends Transource Packing

5/24/2018

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It was both inspiring and heart wrenching listening to Franklin County residents testify in opposition to the Transource Independence Energy Connection during four PUC public hearings this week.  More than 100 people showed up at the first hearing on Tuesday afternoon, and many of them testified under oath.
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Resident after resident stepped up to the microphone to tell the judges how this project would affect them.  We heard about how this project would burden farmland, oftentimes land that has been in the family since the 1800's.  Farmland sometimes serves as a farmer's retirement plan and much of a farmer's wealth is tied up in his land.  A new transmission line across it not only devalues it, but can make it worthless for future uses.  How many people in No. Va., D.C., and Baltimore do you suppose are offering up a part of their retirement savings in order to make power a few cents cheaper each month?  But yet they ask these hardworking farmers to take that kind of hit.

We also heard from a developer who owns a master planned community in Franklin whose beautiful views, property value, and economic well-being will be forever marred by the presence of this transmission line through the valley.

One of my favorites was a professor of economics from a local university who couldn't find any economic benefit for Franklin County, and quoted some absolutely hysterical lines from Paul McGlynn's testimony that made absolutely no sense.

Katie Hess from South Mountain Partnership approached with maps, studies, and other publicly published exhibits and testified at length about how the project would impact farmland, economics of the region, and the environment.  She also shared that she approached Transource early on in the process in an attempt to develop a partnership of sorts to help site the line to have the least impacts.  Transource dismissed and rebuffed her efforts.  I guess they're now reaping what they sowed.  At the end, Transource's attorney objected to her exhibits as "heresay."  Overruled!

The president of the Franklin County Area Development Corporation testified that Transource's claimed economic benefits to Franklin County were biased and perhaps exaggerated.  Based on his many years of experience developing the economy of Franklin County, he said Transource has failed to quantify the benefits and articulate the need for this project.  He also had an amusing Transource story to tell... that the company assumed he would automatically support the project and sing its praises.  However, he is adamantly opposed.  He is the first local economic development professional I have seen to reject a transmission proposal.  I greatly admire his honesty and professionalism on behalf of the people of Franklin County!

And, of course, a union shill showed up.  Funny that... the first person signed up to speak was Bernie Kephart.  Except he wasn't there.  How did his name get on the list?  Did he sign up remotely?  Or did someone else sign his name, hoping he would show up?  Bad form, Transource.  Extremely bad form.  Don't junk up speaker lists with names of people who aren't even present.  And the one union guy who did speak told everyone they wouldn't even notice the power line after it was built.  He got a roar of laughter so powerful even he was laughing as he slunk away from the microphone.  Pretty ridiculous!

Attendance was also high at the three subsequent hearings, with about 100 speakers voicing opposition to the project, and many more filling the venue to support the opposition.  The only ones voicing support for the project were a few union plants and a farmer/transmission construction company owner from another part of the state who says he does $30M of business yearly.  Ya know, Transource, you did a lousy job drumming up fake advocacy for your project.

But who needs advocacy when you have liars like Todd Burns schmoozing up the media?  He actually said PJM "identified a deficiency in the grid."  No, it didn't.  It identified a price differential between the cost of electricity in Pennsylvania and the cost of electricity in Washington, DC.  There's absolutely nothing wrong with the grid.  It is not "deficient."  We don't need to "reinforce the grid."  Liar, liar, pants on fire!

It's time for Transource to pack up all its lies, its exaggerations, its fake claims of benefit, its totally false pretense of "working with the community," its injunctions and abusive, lying land agents and take the whole kit and kaboodle back to Columbus, Ohio.  That's not the way the good people of Franklin County live their lives.  You're not fooling anyone, Transource.  Nobody at all.

I'm pretty sure the PUC administrative law judges left Franklin County with plenty of truth, however.  The citizens came out strong and spoke from their hearts.  That's a big win in the regulatory world!
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Investor Owned Utilities Hope To Make Big Bucks Buying Wind Farms and Building Transmission Lines

5/23/2018

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News Flash, right?  Not really.  Investor Owned Utilities (IOUs) are always hoping to make big bucks -- that's what their investors want them to do.  And making a buck for investors trumps serving the public need every time.  Every.Single.Time.  I'm not sure who ever thought it was a good idea to allow entities who peddle a public service, like utilities, to be investor owned, for-profit, monopoly corporations.  It sort of defies common sense, if you think about it too much.  There are plenty of municipal or co-op utilities that operate on a profit neutral basis, of course that just means that they have to give back anything left over, instead of paying a dividend to investors.  It doesn't necessarily rein in their spending to produce lower rates for customers.

IOUs make money owning stuff.  Sure, they make money supplying you with electricity, but they make the big bucks by owning stuff (for your benefit, of course) that you pay off over a long period of time, with interest.  It works almost like a real estate mortgage.  The IOU (and its investors) put up a sum of cash (or credit) to pay for something like an electric generation station, or a transmission line.  You pay them back for that investment over a period of many decades, often at 10% or higher return (or interest) on your unpaid balance.  Your mortgage statement probably tells you exactly how much principal and how much interest you pay each month.  Your electric bill never does.

And here we are, smack dab in the middle of a changing preference for electricity generation.  Gas is cheaper than coal, and much generation has switched in recent years.  New gas plants mean new IOU assets you will pay for.  And then there's the wind hype.  Greenwashing is also brainwashing people to think they can meet all their electric needs with wind power generated... somewhere else (not in MY backyard!).  And Big Wind (yes, that's a proper noun) is in a huge panic to build, build, build before the federal Production and Investment Tax Credits expires at the end of 2019.  Wind turbines generate money as they turn -- .023 for every kwh produced for their first 10 years of operation.  Wow, what a savings, huh?  Except where do tax credits come from?  Where does the money come from?  It comes from YOU, little taxpayer.  It comes right out of your pocket, and many of the companies receiving these generous credits are foreign corporations.

So, with the big wind push, everyone wants to own one of these money mills, or maybe a big, fat new transmission line to be used to move the kwh generated to willing buyers.  Who are the buyers?  They're the utilities that serve customers.  Pretty much no electric customers buy their electricity directly from a wind farm.  Their utility makes the purchase from the wind farm and re-sells the electricity to you.  But an IOU getting all its power via purchase agreements with companies that own the generator isn't getting that big, fat return on owning the generator, a guaranteed income stream for decades.  The same is true of transmission lines... no IOU wants to pay some transmission company (like Clean Line Energy Partners) for service when it can own the transmission line (and the return) itself.  Note to Clean Line:  This is why you failed!  The IOUs may be slow, but they're not exactly dumb when they smell money.  So it's happened that now it's all the rage for IOUs to buy wind farms and build new transmission lines to connect the wind farms with customers.  The IOU makes a return on the cost of the wind farm, the customers cover all the costs to operate the wind farm, and it also makes a big return on any transmission line it owns (and you also pay operating costs for the line).  And if the IOU can get these deals approved fast enough, they can also collect all the tax credits that fall out of the sky when the turbines spin.  Some companies claim that they will use the credits to make the electricity cheaper for customers, and that with the credits, owning the new generator actually makes electric costs cheaper.  Win, win, win!!!

But IOUs, as monopolies, need the permission of regulators (who are supposed to take the place of competition in a monopoly construct) to recover the costs of buying generators and building transmission lines from customers like you.  American Electric Power was the first big IOU to jump into the pool, asking regulators in four different states to approve their plan to buy the nation's biggest wind farm and build a big new transmission line to connect it, and charge the costs of doing so (and their return, of course) to customers.  AEP's execution is faulty.  Not only did they fail to follow utility regulations that require a competitive bidding process for new generator purchases, but they also couldn't show any true need for the transmission line.  New transmission is planned by regional transmission authorities, who determine a reliability, economic, or public policy need for the project, and then assign costs to users of the new line.  A company who doesn't want to go through the regional planning process to determine a need for new transmission usually ends up as a merchant project, where the company assumes the risk and investors shoulder the cost of building it, with revenue recognized through capacity charges billed to those who use the new line.  But AEP didn't want to assume any risk for its investors, so it asked that regulators approve its transmission line without there being any need for it at all (except to connect the new generator it failed to competitively source).  AEP is stuck in the molasses swamp now and it's doubtful they'll be able to pull this off without some under the table and behind closed door deals.  (The cost of which is NOT billable to customers!!)  AEP's idea failed because it was not smartly executed.

Now our second example was planned much better, over a longer period of time, and not the knee-jerk rush to riches steamroll that AEP attempted.  Ameren got regional planning approval to build a new transmission line across northeast Missouri several years ago.  Supposedly it was needed for reliability and to move renewable electricity across the region.  The project nearly tanked on its first run at approval because it stupidly attempted to route it on new right of way across areas without a transmission line.  But, ever resourceful, Ameren finally recognized its problem and went back to the drawing board to re-route its project on existing rights of way.  And it was approved.

Now Ameren says it wants to buy what will be the biggest wind farm in the state of Missouri, and use the new transmission line to connect it to its customers.  Ameren arranged its big wind buy into distinct and manageable pieces.  First, the transmission line.  Then the wind farm.  If Ameren can pull this off, it will be sitting pretty with two new assets that it can earn a return on for decades.  AEP.... take a lesson in strategy and patience, instead of acting like a bull in a china shop.

Of course, it remains to be seen if this wind farm will actually be built and if Ameren will actually end up owning it.  It also remains to be seen how many more large IOUs try to get into this game before the tax credits dry up.  After that happens, Big Wind is dead.
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Clean Line Sells Off Another Appendage

5/21/2018

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"Across the country, we are seeing clear proof of how building new efficient transmission infrastructure provides substantial benefits for consumers, through the delivery of clean renewable energy at rock bottom prices, job creation, and economic development.  We have worked to bring the Western Spirit Transmission Line and the Mesa Canyons Wind Farm to advanced stages of development in New Mexico, and are very pleased that Pattern Development will now take both projects over the finish line," said Michael Skelly, President of Clean Line Energy Partners.
The only "clear proof" here is that there's a fire sale going on down at the old fire house.  Clean Line is selling off its projects to anyone who will buy them.  And why is that?  BECAUSE CLEAN LINE ENERGY PARTNERS HAS FAILED!

And Clean Line's failure is clear proof that long-distance transmission to export wind energy across regions is not marketable.  There are no customers willing to finance such a transmission project.
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First Clean Line sold the Oklahoma portion of its Plains & Eastern project to NextEra.  NextEra was only interested in the Oklahoma portion.  NextEra wasn't interested in the Arkansas and Tennessee portions, maybe because there were no customers to purchase capacity at that end.

Now Clean Line has sold its Western Spirit Clean Line and the leases for its Mesa Canyons wind farm.  That's two of Clean Line's five project proposals.  Are the other three projects for sale?  Probably, but who would buy them?

The Rock Island Clean Line has been made illegal in Iowa, and the Illinois Supreme Court ruled that Clean Line is not a public utility in that state.  It can't be built.

The Grain Belt Express Clean Line has also been declared not a public utility by an Illinois appeals court.  It can't be built in Illinois.  Maybe it's time to chop that project up and try to sell a portion for pennies on the dollar?

And what of the Centennial West Clean Line?  There's no public information available about progress for that project, therefore there obviously is no progress.  Would someone buy it?

With the sale of two of its five projects now, it sure looks like Clean Line Energy Partners is finished.  If Skelly thinks having doors slammed in his face across the country is "clear proof" that his projects are wanted and needed, he's living in a self-delusional fantasy world.
Each RTO has its own system for modeling and evaluating proposed projects, and nothing is more difficult than deciding who should pay what, according to Mike Skelly, founder and president of Clean Line Energy Partners, the one company currently trying to build long-distance transmission lines in the Midwest. He offered up a restaurant analogy.

“If you go out to dinner and everybody orders different dishes, and you’ve got to figure out who’s gonna pay for what, it gets tricky,” he observed. In the inter-regional transmission world, typically a number of utilities and other customers benefit from new transmission capacity, but no one is eager to pick up the tab.

Skelly said the messy business of dividing the bill is one reason Clean Line has structured its two Midwestern long-distance transmission lines in a way that minimizes dealings with RTOs. It has proposed using DC instead of AC current, will take on power at one location and deliver it to two locations.


“We felt like the inter-regional planning processes didn’t work nine years ago, and they don’t work today,” he said.
Clean Line’s Grain Belt Express would ferry wind energy from Kansas to Indiana – and from the SPP to PJM. The Rock Island transmission line would move wind energy from northwest Iowa to the Chicago area – and from the MISO to PJM. Skelly said he knows exactly who would benefit from the project, and who, therefore, would pay for it: usually the wind farms whose electrons are moving to the east.

Except, those people don't want to pay for it.  So, if Skelly went out to dinner and pretended he had forgot to bring his wallet, could he force the other diners to pick up his tab?  I think Skelly would spend a long night washing dishes.  Or trying to sell his projects to other companies.

The rest of the projects aren't marketable in their current state.  I do make significant note that the sales Clean Line has made were to companies who saw their purchase as a strategic, rather than profitable, move.  If NextEra had an Oklahoma transmission route, it could try to compete with AEP's Wind Catcher project.  If Pattern owns its only competition in New Mexico, then it could be more certain of getting its project built.  Is there any strategic value in Rock Island, Grain Belt or Centennial West?  I believe Skelly is hoping so, because there's no other reason to keep spending money trying to prop up these failed projects to appear viable.  One thing is for certain, nobody is buying the failed Clean Line projects with the intent of building them as Clean Line envisioned.  It's more like buying a beanie baby at the thrift store to use as a dog toy.

Until the next sale....
4 Comments

York County Judge Issues Thoughtful Opinion on Public Utility Trespassing

5/14/2018

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If a privately held utility has been granted public utility status by a state, does that give the company the right to enter any property in the state at any time to perform potentially damaging tests and surveys?  That's the question being considered by judges in the states of Pennsylvania, Maryland, and Oklahoma recently, courtesy of American Electric Power and its subsidiaries.

This issue has rarely come up in the past because transmission public utilities have been able to propose projects, apply for permits, and even receive approval without creating this kind of pitched battle between the utility and landowners.  Utility entry to survey has been voluntary, and landowners who agree have signed survey permission forms releasing the company from liability for incidental land damages.  Even when large numbers of landowners refuse permission, such as happened with the AEP's PATH transmission project, the company was still able to pursue its regulatory applications and route planning because the transmission project didn't have a firm "drop dead" date by which it must be constructed.

Now, however, AEP subsidiaries find themselves involved in two projects that do have firm in-service dates.  Transource's "Independence Energy Connection" has a June 1, 2020 completion date written into its Designated Entity Agreement with PJM Interconnection.  And PSO's Wind Catcher generation and transmission project must be completed by December 31, 2020 in order to qualify for the federal production tax credits that supposedly make it economically beneficial.  Both of these projects have self-imposed hard completion dates, therefore AEP wants to get as much pre-construction surveying and engineering done as possible during the permitting phase.  It's going to take too long to survey and test after regulatory approval and eminent domain authority is granted for these specific projects.  AEP fears it may miss its drop dead dates.

Ya know what, AEP?  You're going to miss both these dates anyhow.  Landowners who use their land as a source of income have another timetable.  These dates were already too ambitious from the start.  Transmission never stays on schedule, as you should well know since you like to parade your 16-year timetable to get your Jacksons Ferry-Wyoming project built as some kind of regulatory, and not personal, failure.

AEP subsidiaries claim to have a right under the law (or even by virtue of flimsy precedent), as public utilities, to enter into any property at any time to conduct tests and surveys.  If it's that simple, why are you asking courts for injunctions to allow entry?  As Judge Richard Renn in York County, PA, opined:
Plaintiff is quick to claim that it does not need any court order to enter upon the lands because it has that inherent right pursuant to the Eminent Domain Code. (Plaintiff's Brief in Opposition to Defendants' Preliminary Objections ... p. 7.) Yet, Plaintiff is here in Court seeking just that -- a court order permitting it and its agents entry onto lands of Defendants.
Why are you wasting time in court, AEP?  Is it because you're really not sure you have such a right?  If you have such a right, why is this the first time this issue has come up?  And why have you been seeking voluntary permission for decades?  If you, indeed, do have such a right, you should have been exercising it for years and not asking landowners to voluntarily sign away their rights.

Judge Renn also took into consideration the nature of the studies and tests, and their specificity to each property.  AEP asked for blanket permission to enter and perform any number of invasive tests, at its own discretion, including the right to cut and trim vegetation and drill holes.
...claiming an immediate need to access Defendants' property for the purpose of obtain[ing] critical information, including various environmental studies, (including, wetland delineations, habitat assessments, and threatened or endangered species surveys), appraisals, geotechnical surveys (including soundings and drillings for testing soil and bedrock, cultural resources surveys, civil surveys (including trimming or cutting vegetation necessary for survey purposes) and all other surveys and tests necessary to properly assess the area, design and construct the proposed electric transmission line ...
(Plaintiff's Motion,~ 22).

From this description, the nature of the proposed intrusion onto Defendants' land appears to be quite extensive, quite possibly resulting in damage to the land. In fact, Defendants acknowledge the possibility of damage by noting in its Motion that it stands ready to pay damages should such occur.
While the law in Pennsylvania states that the utility shall pay for damages, it lacks any specificity to ensure damages are adequately compensated in a timely fashion.  Who shall determine the extent and value of the damages?  When shall payment be made?  What about remediation -- whose responsibility is that?  And what happens if the landowner and the utility cannot agree on damages?  And what about damages that cannot adequately be compensated, such as the cutting of trees that provide a buffer or serve some other economic or sentimental purpose for landowner?  Payment based on their marketability as timber is hardly adequate when the landowner never intended them to be marketable timber.  Who determines the value of lost or spoiled crops?  What's the value of eradicating invasive plant species that are caused by the utility's entry?  What's the value of disturbed top soil or soil compaction and its effect on future crops?  It seems that a little more expertise is required here to determine and price damages other than a utility's self-interested determination of immediate, visible damages and their value.

Judge Renn was not inclined to allow the utility to
disrupt Defendants' peaceful possession and enjoyment of their lands with "soundings and drillings ... [and] trimming or cutting vegetation ... " possibly resulting damages, on the off chance that the power line may, in fact, run over a portion of those lands, with one exception.
That exception being the bog turtle hunts that Transource described with specificity in its motions, because the judge believed them to be non-invasive and unlikely to cause damage.

However, I note that perhaps the turtle hunts may not need to take place on every property.  Does every one of the 36 properties in York County contain a wetland suitable for bog turtles?  And for the ones that do, is there still enough time to perform the surveys according to the published guidelines?  Run, turtles, run!!!

The only thing that Judge Renn didn't deny was the turtle hunts because they were specified as to procedure and he found them to be potentially non-damaging.  The rest of AEP's trespassing wish list has been denied until further consideration and possibly a trial.  Maybe Transource should have just stuck to the turtle hunts to begin with, and not asked for blanket permission to take over and damage private property?

Because that's what AEP is also asking for in Oklahoma.  Blanket permission to perform damaging surveys on an uncertain route for an uncertain project has been recommended for denial by an Oklahoma Corporation Commission judge.  And the only thing they rely on there is precedent where a utility was allowed the right of entry for purposes of preparing its filing of an eminent domain suit.  AEP claims it is actively constructing a transmission line in Oklahoma and preparing eminent domain suits to acquire land for its project, except that's not even close to true.  AEP doesn't even have a certain route yet and the OCC has not determined there is a need for the project or that it will permit the company to charge its costs to ratepayers in the state.  Without cost recovery, AEP will not undertake this project.  It's all about what might happen and AEP is certainly engaging in a land-damaging fishing expedition of the kind Judge Renn denied in Pennsylvania.
We fully realize that the final route may not be able to be approved absent the studies Plaintiff seeks to undertake. However something more than Plaintiff's mere assertions as to whose lands might be affected is required to satisfy us that Plaintiff is not on the proverbial "fishing expedition." We are mindful of Plaintiff's argument that preventing discovery at this stage of the proceedings makes it difficult for it to obtain final route approval. However, our concern is not with what Plaintiff must do to satisfy the PUC, our concern within the context of this litigation in general, and regarding Plaintiff's discovery request in particular, is to ensure that a party does not suffer from "unreasonable annoyance, embarrassment, oppression, [or] burden" during the discovery process.
My understanding is that Oklahoma doesn't approve transmission routes, so what's the reasoning for doing the surveys at this point in time?
PSO will suffer irreparable harm, damage, and injury unless the acts and conduct of Defendants above complained of are enjoined because further work and construction of the
transmission line cannot continue unless the location and description of the right-of-way easement across the Property owned by the Defendants can be determined.
Who you trying to kid here, AEP?  A judge?  You know full well that you're not actually constructing anything and are nowhere near filing condemnation actions.  That costs money AEP doesn't want to spend until it is guaranteed recovery of its costs to construct this project from ratepayers.  And that approval (from four different states no less!) has not happened yet.

And because it just can't help exaggerating and asking for more than it really needs, AEP has requested the Oklahoma judge order landowners to pay for the cost of its overreaching lawsuit.  Do you really want to punish landowners that way for resisting you, AEP?  You think landowners who won't sign your voluntary permission forms and give up their rights should pay for your overpriced lawyers to sue them?  Or did you just add that as an intimidation tactic?  Despicable!

While these fights seem very specific to two AEP projects, the effect of them could potentially be broad.  Should we upend the current status quo that makes survey permissions voluntary until after utility commission review (at which time the commission can issue an approval contingent upon surveys and tests being performed)?  Or should we roll out the red carpet for any utility to enter upon and damage the property of any landowner at any time?  Seems to me if it's the latter then new laws and regulations covering this activity are sorely needed because we will all be subject to corporate dictatorship instead of due process.  Private property rights shouldn't be set aside in favor of corporate profits.
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Citizens Pan Transource at Public Hearing

5/14/2018

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The Pennsylvania Utility Commission is holding public hearings on the Transource Independence Energy Connection proposal to build two transmission lines on entirely new right-of-way in York and Franklin Counties. 

The first day of hearings occurred last week in York County, where many citizens spoke out in opposition to the project.  The citizen opposition was bolstered by comments from local elected representatives.
State Rep. Kristin Phillips-Hill, R-York Township, said the project doesn't show that it will provide "long-term, significant benefits to our local Pennsylvania communities economically, nor preserve our tremendous agrarian heritage and scenic beauty."

She said, "York County is proud of its strong preservation heritage with nearly 42,000 acres and 282 farms."

Phillips-Hill said the question of why two existing high-voltage power transmission lines that run parallel to the proposed route and are not operating at full capacity aren't being utilized hasn't been satisfactorily answered.
Indeed, Rep. Phillips-Hill!  Why is this company proposing a transmission line on new right-of-way when existing infrastructure through the community is only half-utilized?  Can we blame the company, PJM Interconnection, or federal energy planning procedures?  All of the above!  The Feds encouraged competitive transmission projects, where companies compete to build the best project at a bargain price.  And PJM ran a competitive transmission contest to see who could propose a project that alleviated a congestion concern from 2014.  And PJM selected Transource, a new entrant without any existing assets in the geographic area.  And Transource can only build new assets because it doesn't own any existing ones that could be upgraded or rebuilt to economically alleviate the constraint with minimal intrusion on local landowners.  All three of these entities have since conspired to continue to push this outdated idea, even though better alternatives have been recognized.  What good is competition when it costs communities and ratepayers more than upgrading existing assets?  It's nothing more than an exercise in trying to force a solution that is no longer economical because a project looked good on paper once upon a time.  And it's proof that PJM's competitive process does not work on economic projects because the entire exercise takes too long and is subject to public input.  PJM's "market efficiency" competitive transmission planning process is an abject failure that should be abandoned in favor of better, cheaper, less invasive ideas.

I considered the name of this project recently, and the irony is laughable.  "Independence?"  Making Washington, DC, Northern Virginia, and Baltimore dependent upon electrical generators in Pennsylvania rather than generating electricity locally is "independence?"  Independence for whom?  There's nothing "independent" in a transmission project that serves as nothing more than an intrusive leech, sucking resources out of one state to serve a more economically prosperous and politically connected geographic region at the expense of one not so well positioned.  That the economic prosperity of the big cities is proposed to gain at the expense of the economic prosperity of small Pennsylvania communities is wrong, just wrong.

It's up to the Pennsylvania Utility Commission to protect Pennsylvanians, not toss them under the bus in order to provide benefits for citizens of other states.  And you need to tell them so!  The second York public hearing is scheduled to take place today, beginning at 1:00 and 6:00 at the Airville Volunteer Fire Department.

Two additional public hearings will take place next week in Franklin County.
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Please come out and support your community, whether it is giving oral comment, submitting written comment, or simply showing your opposition from the audience.  This may be your only opportunity to have your say, please don't miss it!

See you there!
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    About the Author

    Keryn Newman blogs here at StopPATH WV about energy issues, transmission policy, misguided regulation, our greedy energy companies and their corporate spin.
    In 2008, AEP & Allegheny Energy's PATH joint venture used their transmission line routing etch-a-sketch to draw a 765kV line across the street from her house. Oooops! And the rest is history.

    About
    StopPATH Blog

    StopPATH Blog began as a forum for information and opinion about the PATH transmission project.  The PATH project was abandoned in 2012, however, this blog was not.

    StopPATH Blog continues to bring you energy policy news and opinion from a consumer's point of view.  If it's sometimes snarky and oftentimes irreverent, just remember that the truth isn't pretty.  People come here because they want the truth, instead of the usual dreadful lies this industry continues to tell itself.  If you keep reading, I'll keep writing.


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