Hundreds packed a public open house convened by FirstEnergy Monday night to reveal plans for the Northern Portage Reliability Project.

The big room at Christ Community Chapel was built to hold 350 and it was so packed that people were turned away within the first half-hour of what was to be a two-hour event.
As the open house began at 6 p.m., traffic was backed up for almost half a mile between the chapel just off Ohio 306 and Ohio 82 to the south.

FirstEnergy employees, contractors and consultants staffed themed tables around the periphery of the room. They included stations entitled Engineering & Construction, Vegetation Management, Environmental, Real Estate and Route Selection. The company created a large centerpiece with big photos on easels showing various points where the company wants to put in power lines. The event was designed for people to circulate, but the crowd made navigation around the room difficult. Some attendees complained that there was no public give-and-take between the company and residents as one might have at a town-hall style event.

According to FirstEnergy, the cost to run the lines underground along the rail corridor would be three to seven times more expensive than using utility poles.

First Energy has said the underground scenario could create a 10-fold increase in the cost of the project and the above-ground rerouting would be longer that the former rail line, and would send the lines over roadways and home owners’ yards.

Jennifer Young, a spokeswoman for the company, said the lines will be carried by 60-foot wood poles and those might be reduced to 45 footers, making them lower than nearby trees.

Beach said FirstEnergy measures the viability of various routes by their potential impact on property owners. The western route could affect 111 homeowners (although the company would need right-of-way access from about half that number), and the eastern route could affect up to 177 homeowners with right-of-way access from half that number. He also said many of those properties would have utility poles going up in the front of their properties.

“We have the opportunity to build this and maintain it in the right-of-way with one parcel that’s 100 feet wide for the most part,” said Beach.

We find discrepancies between the General Advertising amounts reclassified by PATH in its Compliance Filings compared to the General Advertising amounts the Commission required PATH to reclassify in Opinion No. 554.

On compliance, PATH must eliminate all General Advertising costs from its recoverable amounts, or else specifically justify each item in light of Opinion No. 554.  In making the compliance filing, PATH must provide the journal entries to reflect the adjustments, and workpapers necessary to explain the accounting corrections for that FERC Form No. 1 input that references back to the journal entries; and the revised/corrected draft Form No. 1 inputs.

Did you make a compliance filing, PATH?

No!  We don't need to!  We made an informational filing!

Are you sure you don't need to make a compliance filing, PATH?

No!  FERC meant an informational filing, not a compliance filing!

Where's our $70M?

PATH must submit a compliance filing with the Commission describing either:  (1) its plan for ending its operations and a timeline for when it intends to file a notice of cancellation of its transmission formula rates, or (2) the type of “transmission or sale of electric energy” that requires its rates to stay in effect.  We direct PATH to submit this compliance filing within 30 days of the date of this order.  To the extent that PATH intends to unwind, PATH must make the appropriate filings under FPA section 205, as necessary, to implement this action.  PATH shall notify the Commission within 10 days of the date that the closing out of business is complete.

FirstEnergy is planning to construct a new 69-kilovolt transmission line to connect two substations in the Aurora area.  This new line will improve system redundancy and reliability, allowing much faster restoration times should power outages occur like those in recent years.

“The Maryland Public Service Commission will hold the hearings on our application (Potomac Edison) for a Certificate of Public Convenience and Necessity to modify the transmission line from the existing 138 thousand kV transmission line to a 230 thousand  kV transmission line,” said Todd Meyers, Potomac Edison spokesman.  “There’s a possibility that another much larger transmission that is under consideration, and I don’t know that exact route, and it has two pieces.  And one of the pieces, the more westerly piece runs from an area in Franklin County and it would run down into our Catoctin substation, which is in Smithsburg.”

"We strongly disagree that JCP&L failed to prove the need for the Monmouth County Reliability Project," the utility said. "The initial decision contradicts the findings made by the regional grid operator and industry experts."

I FIND that the preponderance of credible evidence proves that JCP&L commenced studies to justify the MCRP as its preferred route months before any “problem” was even identified as needing a solution.

During the hearings, PJM concurred that JCP&L will not suffer any financial penalties if the Board rejects the MCRP. Both PJM and JCP&L agree that if the MCRP is not approved, they will return to the planning stage and find another way to solve the P7 contingency.

There were four alternative 230 kV lines into Red Bank on the narrowed list but apparently no technical studies were undertaken of them because they were considered by JCP&L to lack the appropriate level of “robustness.” Palermo could not find any definition for that term and was unfamiliar with its use generally in the transmission industry.

Applying these standards, I FIND that Dr. Moliver’s expert opinion is entitled to greater weight than that of McHale. I FIND that McHale’s credibility was undermined by his careless quotation of synopses of studies he never read. He utilized a general search engine that returned results for terms “effect of HVTL at 15 ft” and followed a link to a New Hampshire Siting Commission webpage, copied the summaries, and deleted the attribution footer from his reprint. As reluctant as I am to express this, in my opinion, such “scholarship” by a student would produce an “F” and subject one to claims of plagiarism. It is certainly not the work product of a professional entitled to much weight to count the number of supportive studies versus the number of unsupportive studies without regard for the study criteria and quality. The merits, depths, sampling size, and commonality must be taken into account before a study can be cited as persuasive to a novel setting. I also FIND that his opinion as an expert witness was blended with several lay perceptions that fell outside the scope of his presentation for the Company and were unverified.

The evaluation directed by JCP&L was both pre-emptive in the timeline of the “need” for the Project and created an unlevel playing field tipped in its obvious favor. This is not a close case of general public interest versus parochial interest, with a tie going to the public utility company. I CONCLUDE that JCP&L’s application for municipal waivers pursuant to N.J.S.A. 40:55D-19 must be denied because the Company has not supported its application by the preponderance of the relevant and admissible evidence. The MCRP is not a safe or reasonable response to the potential P7 violation.

The prepared summary of written statements indicates that eighty-three (83%) percent were opposed to the MCRP; and, seventeen (17%) percent in favor. Approximately twenty-five (25%) percent of the statements opposing the Project were form letters; and ninety-two (92%) percent of the statements in favor of the Project were form letters, of which eighty-eight (88%) percent were not from the impacted area.

Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it's the only thing that ever has.  --  Margaret Mead

The CAD takes no prisoners in its attempt to “advise” the Commission of its responsibilities. In its Reply Brief, the CAD emphasizes the gravity of the situation by stating that, if this Transaction is approved, “the harm that redounds to West Virginia captive ratepayers will be a legacy of this Commission.”

Additionally,the Companies will not accept the conditions included in the Commission Order that would result in Mon Power assuming exposure and significant commodity risk, which is inconsistent with FirstEnergy’s announced corporate strategy.

First, the rate benefit to residential ratepayers is a one year benefit of $11.52. The Companies provided no evidence of rate impacts beyond December 2018. The absence of this information is intentional.

As originally proposed by the Companies, if the acquisition of Pleasants is approved, there will be a $31,486,971 net decrease in rates for the 16-month period of September 1, 2017 through December 31, 2018, which is a 1.6% overall decrease. Residential customers would experience a decrease of about 0.9%. The decrease for a residential customer using 1,000 kilowatt-hours per month would be $0.96 per month, which would result in a decrease to $111.52 from 112.48 per month.  It is important to note that the decrease in customer rates is guaranteed only through December 2018.

West Virginia captive ratepayers are not hedge managers or virtual traders in the PJM markets. If the Commission approves this transaction that is what they will become: buyers of significant surplus capacity that Companies are betting (on their behalf) will provide benefits for years into the future. Pleasants was rejected by FirstEnergy as too risky. The overwhelming evidence in this case contradicts all Companies’ claims that there will be any benefits to captive ratepayers. Now FirstEnergy wants Companies to manage that risk for 500,000 ratepayers. As the legal representative of ratepayers, no thank you. The Pleasants acquisition should not be approved.

The CAD must begin by emphasizing that if this transaction is approved the harm that redounds to West Virginia captive ratepayers will be a legacy of this Commission.

The participation of Mr. Sims [PJM witness] in this proceeding as an enthusiastic cheerleader for an expensive and blighting transmission project even after being presented with a feasible non-generation solution to the P7 contingency raises very serious questions about the neutrality of PJM. As is the case with other RTOs, PJM is by law and FERC decisions supposed to be scrupulously neutral.  While this is ordinarily taken to mean that it cannot discriminate in favor of one or more member utilities or independent power producers, it also means that PJM cannot be in the business of advocating a solution that has been given an “exclusive” to one of its member utilities. The Board should express condemnation of PJM’s role in this case.

During testimony, RAGE unveiled its alternative to the transmission line plan — an alternative the group says would cost 70 percent less, and present less danger to the community.

The group’s solution, backed by a power flow analysis and an engineering expert, includes the addition of two STATCOM devices — each about the size of an RV — at the Red Bank substation. It also calls for updating 11 of the existing 34.5 kV lines coming out of Red Bank.

“That’s it — all you need to do is update some existing lines that probably need replacing anyway, and add two big boxes to Red Bank, Kanapka said. “Do these two things and the P7 violation goes away, for a total estimated cost of just $30 million.”

In its most recent estimate, JCP&L said their project could cost $111 million, and that does not include the fee for usage of NJ Transit’s property.

I fear all we have done is to awaken a sleeping giant and fill him with a terrible resolve.

The design principles and practices that create energy resilience (or, as the Secre­tary calls it, resiliency) were first framed for the Penta­gon in 1981, and still broadly guide DoD doctrine for resilient power supplies to military bases and other facilities critical to national security. These principles do not include continued or enhanced reli­ance on inherently vulnerable powerlines hauling electric­ity hundreds of miles from remote central power stations—a system rife with single points and modes of failure re­quir­ing costly redundancies but still not fully effective, as these comments elaborate. Such grid-dependence is the largest factor preventing electric resilience.

Rather, resilient design logically starts at the customer and works back up the supply chain, seeking to make that chain as short as possible and each of its links robust, redundant, with graceful failure and quick rerouting or repair. As a lay summary of Brittle Power explained, a resilient system “has many relatively small, dis­­persed elements, each having a low cost of failure. These substitutable compo­nents are interconnected not at a central hub but by many short, robust links. This configura­tion is analogous to a tree’s many leaves, and each leaf’s many veins, which prevent the random nibblings of insects from disrupting the flow of vital nutrients.”

Thus the NOPR’s obsession with continuity of fuel supply to generators—even if 2.1–2.4’s rebuttals below were invalid—ignores the grid. Yet any rational treat­ment of electric reliability and resilience must focus primarily on the grid.
 
The Electric Power Research Institute long ago estimated, and modern data agree, that roughly 98–99% of power failures originate in the grid, and ~90–95% of those in the distribution grid. As the NOPR’s §II(A) rightly notes, Ameri­ca’s grid compris­es 707,000 miles of high-voltage transmission lines, 55,800 substations, and 6.5 million miles of local distri­bu­tion lines. All are interruptible by high winds, lightning, ice storms, tree limbs, cars crashing into power poles, squirrels, birds, operator errors, fires, solar storms, electro­magnetic pulses, cyberattacks, or rifle bullets.
 
As I write this, about three million Puerto Rican American citizens face months of further blackout, with only 16% returned to service after three weeks, because a hurricane destroyed their grid, even though their 98%-fossil-fueled utility has ample and available generating capacity with adequate fuel on hand. The NOPR is irrelevant to them and to the other Americans blacked out in Texas by Harvey, Florida by Irma, the Virgin Islands by Irma and Maria, etc. Hurricane Maria’s grid destruction in Puerto Rico alone has already about doubled in 2017 the total outage cus­tomer-hours experienced nationwide in 2016.
 
Yet the NOPR says and does nothing about the brittle grid connecting power plants to customers—only the virtual non-problem of how big a pile of coal sits at each plant. The NOPR does vigorously seek to prevent and reverse the competitive mar­ket exit of outdated plants typically sited half to several states away from cus­tom­ers, hence inherently vulnerable to grid failure. The NOPR’s effort to reverse the market-driven decentralization and diversification of historic grid depen­dence would weak­en national security: since grid failures dominate total failures, any electricity strate­gy that perpetuates and increases reliance on remote central power plants, no mat­ter how reliable they are, will increase vulnerability and reduce resilience.