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Billionaires' Club Looks Out For Its Own Interests First

5/11/2017

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Who's looking out for your interests, little electricity consumer?  Is there some government agency taking an interest in ensuring that the rates you pay and the services you receive are fair?  Or are privately-funded, self-anointed "consumer interest" groups the ones working in your best interests?  And what's the difference, anyhow?

Public Citizen claims to be a public interest consumer organization.  Public Citizen's energy program has engaged over the years in a series of protests and interventions that spend more time whining about its lack of public funding that hinders its participation than actually saving real dollars for energy consumers.  Public Citizen's most recent whine was highlighted in an article in RTO Insider this week.  Public Interest Groups Cry Foul over Technical Conference, RTO Transparency links to a letter sent to RTO/ISOs and FERC complaining about being denied an opportunity to speak at a Technical Conference.  Public Citizen also launches into its tired arguments that it should be paid to participate in energy regulatory proceedings and should receive  voting rights at RTO/ISOs.

State Consumer Advocates already participate in RTO/ISO processes, and also represent consumer interests before FERC.  State advocates are government employees with the sole mission of protecting consumer interests.  They don't accept outside funding, and in fact currently operate on shoestring state budgets.  These hardworking, underfunded advocates truly have the best interests of consumers in mind.  How do I know this?  Because I shared a counsel table with them during a 15-day FERC proceeding.  I saw and heard a lot.  Consumers saved nearly $20M in that case.

Public Citizen, on the other hand, is a private organization funded with grant money.  Public Citizen's interests are the interests of their funders.  When I looked at who funds Public Citizen, I found a list of individuals and foundations who donated buckets of money to the organization.  While Public Citizen claims to represent thousands of consumer members (who remain nameless) and "low-income" citizen interests, regular folks aren't the ones donating obscene sums of money to Public Citizen.  Under the category of "Foundations" there's plenty of private interest money to be had, such as the Energy Foundation.  The Energy Foundation seems to have an interest in environmentalism.  And, wouldn't you know it, Public Citizen's "Climate and Energy" program seems dedicated to clean energy (not necessarily saving consumers money on their energy bills).   The Energy Foundation seems to be a conduit for billionaire environmentalists to hide while funneling money to private organizations eager to do their bidding.  The Energy Foundation seems to have its fingerprints on a lot of "clean energy" initiatives, such as America's Power Plan (APP).  APP was concocted several years ago to blow some smoke over the issue of using eminent domain to site energy facilities on private property.  The Energy Foundation's assembled "experts" (including Farmer Jimmy Glotfelty of Clean Line Energy Partners) tried really hard to purport to know what landowners wanted in exchange for hosting energy infrastructure on private property.  Except no landowners participated in their project.  As a result, APP got things horribly wrong, such as this gem:
I want to site a new transmission line, but I am struggling to find the best way to work with private landowners who will be affected. Any suggestions?

Look to successful examples from around the country—like Montana Dakota Utilities and Clean Line Energy Partners. And consider new options to bring landowners to the table in a positive way—like Special Purpose Development Corporations or annual payments.

The first principle is to engage landowners early and often. Many utilities have found that holding landowner meetings earlier and more often than required can dramatically improve project efficiency. Innovative ideas include compensating private landowners via Special Purpose Development Corporations (which offer equity in the project’s success) or annual payments (which give landowners a stake in the life of the project). For example, Clean Line Energy Partners is now offering annual payments to landowners who will host a new DC transmission line intended to deliver 3.5 GW of power from Iowa to Chicago.

Of course, eminent domain often becomes an option once a transmission developer demonstrates that a new project is needed and the siting authority confirms that the project will serve the public interest. But cross-state transmission lines and third-party (non-utility) developers cannot always count on eminent domain. Regardless of whether eminent domain is an option, it should always be considered a last resort as there are many options to bring private land-owners to the table in a more positive way that can minimize friction in siting new lines. For example, Montana Dakota Utilities has not had to use eminent domain since 1983, mainly because the utilities consider themselves a part of the community, and have formed positive, trusting relationships with landowners.

For a more detailed treatment of these issues and further options for compensating private landowners, see pages 18-21 of Siting: Finding a Home for Renewable Energy and Transmission.
Successful examples from around the country?  Clean Line Energy Partners?  Hahahahahaa!  Clean Line Energy Partners has had no success, and landowner opposition groups continue to fight them every step of the way.  If you really want to site a transmission line, Clean Line could only be a realistic example of what not to do.

Well, now, how did I get so off track?  "Clean energy" is  like peeling an onion... there are so many layers when you drill down into where they get their funding.  The Koch brothers would be proud.

So, let's get back on track here.  Dueling consumer advocates.  The state Consumer Advocates we already have are doing a good job.  "Public Interest Organization" consumer advocates are an unnecessary addition to the fray, and may not have the interests of actual consumers in mind.  This was demonstrated quite clearly in a recent FERC proceeding that pitted Public Citizen against the West Virginia Consumer Advocate.  The subject was a PJM Interconnection rate case.  Public Citizen intervened and whined about PJM's costs and said that consumer advocates aren't allowed to participate at PJM.  West Virginia Consumer Advocate Jackie Roberts intervened and filed a comment disagreeing with Public Citizen's contentions about Consumer Advocate participation in PJM's budget.  In fact, consumer advocates do participate in PJM's budget process, as well as being voting stakeholders in all PJM's processes.  Not to be outdone, Public Citizen filed an answer, claiming that state consumer advocates don't represent Public Citizen members, and therefore there was also room at the consumer advocate table for PIOs like Public Citizen.  I don't think anyone is stopping Public Citizen from participating in any regulatory or RTO process, just like any other PIO, such as Sierra Club, or NRDC.  What Public Citizen likes to whine about is the fact that there is no public funding for its participation.

Talk about trying to board the gravy train...  since when are any PIOs publicly funded by ratepayers through the federal regulatory process?  And if they were, how many PIOs would belly up to the bar?  The bottom line is that PIOs do their own thing according to the wishes of the people and foundations that fund them.  That is not "public" interest.  That's a private interest masquerading as a public servant.  Nobody is minding the store to ensure that PIOs truly serve public interests.  Therefore, they don't deserve public funding, or special concessions to allow them to have the same rights and privileges as state consumer advocates.

Federal regulators should think twice about opening Pandora's box with a pile of public funding offered to anyone who wants to call themselves a "public interest organization."  The queue to score some public funding to advance private interests would probably wrap around the National Mall several times.

Maybe Public Citizen should concentrate on actually delivering some documented savings to electric consumers before whining that it needs public funding to protect consumer interests.  The proof is in the pudding.
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Eighteen million six hundred thirty three thousand one hundred twenty four ratepayer bucks

3/21/2017

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Eighteen million six hundred thirty three thousand one hundred twenty four ratepayer bucks in the till...

Eighteen million six hundred thirty three thousand one hundred twenty four ratepayer bucks...

Take one out, refund to ratepayers, eighteen million six hundred thirty three thousand one hundred twenty three ratepayer bucks in the till.

Eighteen million six hundred thirty three thousand one hundred twenty three ratepayer bucks in the till...

Eighteen million six hundred thirty three thousand one hundred twenty three ratepayer bucks...

Take one out, refund to the ratepayers, eighteen million six hundred thirty three thousand one hundred twenty two ratepayer bucks in the till.

PATH made its compliance filing yesterday, as ordered by the Federal Energy Regulatory Commission on January 19th.  FERC ordered the company to recalculate the rates it has collected from electric ratepayers since 2008 to correct errors it made and refund amounts collected in error.

Here's the money quote.  Literally.
For Rate Year 2008 through Rate Year 2015, PATH has calculated that refunds, with interest, will amount to $18,633,124.
The refund includes errors PATH made in the recording of public relations expenditures, advertising, lobbying, and other expenditures for the purposes of influencing public officials, such as recruiting support for the project at public hearings and signatures on petitions supporting the project.  It also includes errors on the effective date of recovery of abandoned plant, and errors in calculating depreciation of assets.  The refund includes interest on amounts collected in error, and adjustments to the company's return on equity due to the adjustment of capital account amounts.

Do you think PATH managed to correct its errors without making further errors in its corrections?

Eighteen million six hundred thirty three thousand one hundred twenty two ratepayer bucks in the till...

Eighteen million six hundred thirty three thousand one hundred twenty two ratepayer bucks...

Take one out, refund to ratepayers, eighteen million six hundred thirty three thousand one hundred twenty one ratepayer bucks in the till.
Eighteen million six hundred thirty three thousand one hundred twenty one ratepayer bucks in the till...

Eighteen million six hundred thirty three thousand one hundred twenty one ratepayer bucks...

Take one out, refund to ratepayers, eighteen million six hundred thirty three thousand one hundred twenty  ratepayer bucks in the till.

Eighteen million six hundred thirty three thousand one hundred twenty ratepayer bucks in the till...

Eighteen million six hundred thirty three thousand one hundred twenty ratepayer bucks...

Take one out, refund to ratepayers, eighteen million six hundred thirty three thousand one hundred nineteen ratepayer bucks in the till.

Eighteen million six hundred thirty three thousand one hundred nineteen ratepayer bucks in the till...

Eighteen million six hundred thirty three thousand one hundred nineteen ratepayer bucks...

Take one out, refund to ratepayers, eighteen million six hundred thirty three thousand one hundred eighteen ratepayer bucks in the till.

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PJM Doles Out the Punishment

3/17/2017

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Well, isn't that fun?  PJM is punishing everyone because it's not getting its way.  Well, really Dominion's way, but PJM and its utility members are just different parts of the same animal.

Dominion finds itself mired in controversy over its Surry-Skiffes Creek 500kV transmission project in Virginia's tidewater region.  The project as proposed would make an aerial crossing of the James River quite near the historic Jamestown settlement.  The people say no.  The National Parks Conservation Association says no.  The National Trust for Historic Preservation says no.  The Army Corps of Engineers, who has to approve the project, isn't saying anything at all.  And we have stasis.

So, Dominion called in its trained gorilla, PJM, to terrorize the townsfolk and make them drop their opposition.  As if that kind of behavior ever works in a situation like this.  The people simply said "meh" to PJM's threats of rolling blackouts.

Now PJM has devised a way to punish them with higher electric rates.  And it has upped the ante by punishing everyone else in the PJM region with higher rates as well.  PJM has assigned cost responsibility for keeping generation units on the Virginia Peninsula running after they would have shut down not only to the folks on the Peninsula, but to every other zone in the PJM region.  That's right, electric customers in Illinois, New Jersey, Pennsylvania, Ohio, Kentucky and other PJM states will pay a percentage of the cost of running the units that wanted to retire.  PJM says:
Based on PJM’s assessment of the contribution to the need for, and benefits expected to be derived from, the facilities, the zonal percentage cost allocation for 2017 (January 1, 2017 through April 15, 2017) is...
...followed by a table of allocation percentages.  I'm going to be paying 3.5%.   Meh.

Trade press RTO Insider says
Opposition to Va. Tx Line May Trigger Unintended Consequences

Sometimes the juice isn’t worth the squeeze.

Protesters of a 500-kV transmission line across the James River might soon learn that the hard way. PJM is responding to the delay in the project’s approval by instituting a multilayered strategy likely to hurt ratepayers in Virginia’s middle peninsula disproportionate to any perceived benefits that could come from blocking construction of the line.

At a series of committee meetings last week, PJM staff detailed several other changes for the area that will have consequences protesters likely haven’t imagined.
Like outrageous electric price spikes.
Really, PJM?  Whose interests do you serve again?  You think hitting senior citizens, and other folks who may just barely be scraping by, with surprise outrageous electric bills, and then blaming the opponents of a transmission line, is really going to work for you?

I thought PJM's purpose was:
Acting as a neutral, independent party, PJM operates a competitive wholesale electricity market and manages the high-voltage electricity grid to ensure reliability for more than 65 million people.
But it sure seems like PJM's purpose lately is to ram through the projects cooked up by its members without any room for compromise with the people who have to live with them.

Who would be hurt by a change to an underground/underwater project?  Oh, too expensive for the ratepayers, you say?  Well, what about your scheme to gouge ratepayers as punishment for opposing the project?  Won't that be too expensive?  Seems like the ratepayers are going to pay more either way, so why don't you just fall on your sword and cap the damages with a buried option?  At least that would come with a finite number, over the life of the project, instead of giving Grandma a nasty surprise she can't pay for.

And speaking of outrageous costs, PJM, who did you fool with your recent re-start of your Artificial Island project, after removing certain components to lower the overall cost?  I don't think it was ever about the amount... but the fact that the cost was allocated to people who would not benefit.  That hasn't changed.  Good luck with that!

Stop being stubborn, PJM.  You exist to serve the people, not the energy corporations.  It's getting harder and harder to build transmission, and do you know why?  Because the people aren't as easily fooled in this day and age of readily available, unfiltered information.  Badly conceived projects will no longer be tolerated.  So, get with the times, PJM, and recognize that compromise gets the job done.  Quicker.  Faster.  Cheaper.  Easier.  Now is not the time to act like a stubborn mule.

You know, this statement is completely ludicrous.
PJM works closely with stakeholders throughout the development of the RTEP. Stakeholder input is a key part of the PJM planning process. The Skiffes Creek project was reviewed in numerous open meetings of the PJM Transmission Expansion Advisory Committee where public comment was sought prior to approval of the project by the PJM Board. As part of that process, Dominion transmission staff provided PJM its own thorough and comprehensive analysis of system needs as well as potential solutions for PJM consideration. Most importantly however, the Dominion analysis, which itself was based on PJM’s initial determination of reliability criteria violations that needed to be addressed, was then independently validated by PJM and publicly vetted through the PJM stakeholder process prior to PJM recommending Board approval of the Skiffes Creek project.
Public comment was sought?  How did that happen, PJM?  Did you contact community leaders and ask for their comment?  Did you perhaps take out an ad in the local paper soliciting public comment about the project?  Did you go door-to-door and take a public poll?  Of course you didn't.  PJM doesn't interact with the public in any way while considering a transmission project.  It doesn't seek public comments... it simply accepts (and ignores) the comments of any "public" that may somehow happen to accidentally find their way into a PJM TEAC meeting.  The idea that PJM is a publicly accessible stakeholder-driven process is as bogus as it's ever been.  It's time to come out of the shadows, PJM, and interact with the scary public, instead of simply devising ways to punish them for defying you. 
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What Happens When a PJM Project Fails to Meet Milestones?

2/26/2017

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Grassroots group Residents Against Giant Electric (RAGE) continues its outstanding work against FirstEnergy's Monmouth County Reliability Project (MCRP) in urban New Jersey. 
In a recent article (and video) former NJ Transit vice-chairman Bruce Meisel vehemently opposed the MCRP, calling it "... a money grab project that puts the interests of JCP&L over the residents and ratepayers of Monmouth County.”

The significance of Meisel's opposition stems from MCRP's proposal to use New Jersey Transit's right of way for its project.  Without the approval of the NJT board, this project isn't happening.

The article says Meisel was most affected by the number of signs and the people opposing the project across the area when he took a tour of the area late last year.  That's directly attributable to the work of RAGE, who have been very effective winning the hearts and minds of the community and local governments.

If FirstEnergy thinks it can shout down this kind of opposition with a few well-paid business or labor advocates, its got another think coming.  There's nothing FirstEnergy can do to stem the tide of opposition to its project.  It's over.  MCRP lost.  Projects with this kind of political opposition never get approved.  Time for Plan B.

In recent press, FirstEnergy has been turning with increased frequency to what it may feel is its most powerful weapon... PJM Interconnection.
JCP&L has been consistent on the project’s need, which stems from a decision made by PJM Interconnection, a regional grid operator that oversees 13 states and the District of Columbia – New Jersey being one of those 13. PJM has stated that a 2011 review found that Monmouth County’s electrical system violates reliability criteria.
FirstEnergy has quickly gotten to the bottom of its bag of tricks and pulled out what it may feel is its trump card.  PJM says it's needed and therefore there is nothing anyone can do about it.  FirstEnergy wants its opposition to believe that PJM's approval of the project is the final word and that there are no alternatives.  FirstEnergy wants its opposition to believe PJM is an omnipotent authority whose word can never be questioned.

Most people have never heard of PJM.  PJM is a mystery to the average electric consumer, and after years of watching the PJM dance, I'd have to conclude that PJM likes it this way.  PJM has never seen any value in making itself understandable and accessible to the consumers it serves.  While touting itself as "transparent" and open to any "stakeholders," PJM is a hopelessly bureaucratic and technical maze that electric consumers aren't supposed to figure out.  Sort of like this guy:
PJM describes itself as:
PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of wholesale electricity in all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia.

Acting as a neutral, independent party, PJM operates a competitive wholesale electricity market and manages the high-voltage electricity grid to ensure reliability for more than 65 million people.

PJM’s long-term regional planning process provides a broad, interstate perspective that identifies the most effective and cost-efficient improvements to the grid to ensure reliability and economic benefits on a system wide basis.

An independent Board oversees PJM’s activities. Effective governance and a collaborative stakeholder process help PJM achieve its vision: “To be the electric industry leader – today and tomorrow – in reliable operations, efficient wholesale markets, and infrastructure development.”
PJM's planning process uses NERC criteria to define reliability violations that must be remedied.  Who is NERC?
The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to assure the reliability and security of the bulk power system in North America. NERC develops and enforces Reliability Standards; annually assesses seasonal and long‐term reliability; monitors the bulk power system through system awareness; and educates, trains, and certifies industry personnel. NERC’s area of responsibility spans the continental United States, Canada, and the northern portion of Baja California, Mexico. NERC is the electric reliability organization for North America, subject to oversight by the Federal Energy Regulatory Commission and governmental authorities in Canada. NERC’s jurisdiction includes users, owners, and operators of the bulk power system, which serves more than 334 million people.
Had enough acronyms yet?  This industry loves acronyms, it's their own special language that you aren't supposed to understand!

So, NERC sets reliability standards, and PJM uses NERC's standards in its planning process.  PJM and NERC are membership organizations.  Who are their members?  Companies with an interest in the work of the organization.  The industry sort of regulates itself within these organizations.  If the organizations are controlled by their members, and their members are the industry, then PJM and NERC are controlled by the companies they regulate.  PJM didn't use NERC violations to design the MCRP.  FirstEnergy proposed the MCRP to resolve NERC violations that showed up in PJM's 2011 planning process.  PJM simply rubber stamped the incumbent utility's solution to the problem, and nobody proposed any alternatives or spoke against it, therefore it was "ordered" by PJM's Board of Managers.

In its application to the NJ BPU, FirstEnergy says MCRP was the remedy for NERC N-1-1 (or Category C) violations.  If you stack up the different types of violations, N-1-1 comes at the bottom of the stack.  N-1-1 relies on a reliability comedy of errors to occur -- that one component of the system fails, and then a bunch of other components that were supposed to act as back up for that component also fail.  FirstEnergy describes the necessity for MCRP like this:
In the 2011 RTEP, PJM identified reliability criteria violations of NERC Category P7 (previously NERC Category C) contingencies for the outage of the Atlantic-Red Bank (S1033) 230 kV line and the No. 2, 230-34.5 kV transformer with the loss of the Atlantic-Red Bank (T2020) 230 kV line and the No. 8, 230- 34.5 kV transformer due to failure of a common structure containing both circuits. JCP&L confirmed this contingency may result in more than 700 MW of load loss, well above the 300 MW loss of load criterion limit, which violates the JCP&L Planning Criteria as well as PJM planning criteria. The JCP&L-proposed Project was confirmed by PJM that it adequately addresses the reliability criteria violation.
So, one transmission line is out, and then a transformer fails, and then another transmission line goes out, and then another transformer fails.... and then you need the MCRP to provide service.  That's 2 transmission lines and 2 transformers, all out of service at the exact same moment.  Chances of that happening?  Not likely, but it could happen, in theory.  However, it's not likely that failure to build the MCRP as proposed is going to make the lights in New Jersey go off in the near future.  Because if we want to play the "what-if" game, what if the MCRP also fails after the other 2 transmission lines and the other 2 transformers fail?  But NERC doesn't go that far out in its "what if" game, because it starts to get a little ridiculous.... and expensive.

A NERC violation was identified by PJM, FirstEnergy's JCP&L came up with a "back of the envelope" solution, PJM's Board of Managers approved the solution and assigned construction to JCP&L with a June 1, 2016 in-service date.  And then JCP&L began trying to implement their proposed solution.  The next year, JCP&L notified PJM that they couldn't get it done in time and proposed an extension of the in-service date to June 1, 2017.  And then JCP&L notified PJM a second time that the projected in-service date is now June 1, 2019.  In its application, FirstEnergy shares
PJM has not changed their required date for the project, but has listed the projected in-service date as June 1, 2019 in the RTEP Transmission Construction Status database... Note the PJM Required Date is the date the violation is initially identified to occur.
Apparently the violation keeps slipping out in time to keep pace with JCP&L's failure to get its proposed project accomplished.  How convenient!  I guess this "violation" isn't as urgent as FirstEnergy claims.  If the two transmission lines and two transformers fail tomorrow, PJM will still be able to keep the lights on using other components of the system.  But if the failure happens on June 1, 2017 (or 2019?), the lights will go out unless MCRP is there to pick up the slack.  Seems pretty improbable, doesn't it?

Nevertheless, as a member of PJM, FirstEnergy's JCP&L was assigned construction responsibility for the MCRP.  Membership comes with responsibilities.  Members pledge to follow PJM's operating rules, such as constructing projects which they are assigned.  The PJM Operating Agreement obligates the member to build, but it also gives the member an "out" if things go wrong with the project, such as a failure to secure required state or local permits.
1.7 Obligation to Build.
(a) Subject to the requirements of applicable law, government regulations and approvals, including, without limitation, requirements to obtain any necessary state or local siting, construction and operating permits, to the availability of required financing, to the ability to acquire necessary right-of-way, and to the right to recover, pursuant to appropriate financial arrangements and tariffs or contracts, all reasonably incurred costs, plus a reasonable return on investment, Transmission Owners or Designated Entities designated as the appropriate entities to construct, own and/or finance enhancements or expansions specified in the Regional Transmission Expansion Plan shall construct, own and/or finance such facilities or enter into appropriate contracts to fulfill such obligations.
PJM monitors the project's progress to meet certain milestones.
1.5.8 (j) Acceptance of Designation. Within 30 days of receiving notification of its designation as a Designated Entity, the existing Transmission Owner or Nonincumbent Developer shall notify the Office of the Interconnection of its acceptance of such designation and submit to the Office of the Interconnection a development schedule, which shall include, but not be limited to, milestones necessary to develop and construct the project to achieve the required in-service date, including milestone dates for obtaining all necessary authorizations and approvals, including but not limited to, state approvals.
 
1.5.8 (k) Failure of Designated Entity to Meet Milestones. In the event the Designated Entity fails to comply with one or more of the requirements of Section 1.5.8(j); or fails to meet a milestone in the development schedule set forth in the Designated Entity Agreement that causes a delay of the project’s in-service date, the Office of the Interconnection shall re-evaluate the need for the Short-term Project or Long-lead Project, and based on that re-evaluation may: (i) retain the Short-term Project or Long-lead Project in the Regional Transmission Expansion Plan; (ii) remove the Short-term Project or Long-lead Project from the Regional Transmission Expansion Plan; or (iii) include an alternative solution in the Regional Transmission Expansion Plan.

PJM isn't so much wedded to a certain project as it is compelled to find a solution to impending violations.  A project that fails to be permitted goes back to the drawing board, and PJM works with the utility to find an alternative solution that can be permitted.  Ill-conceived projects that draw staunch, sustained and wide-spread opposition rarely get permitted.  Who's monitoring JCP&L's "milestones" on the MCRP project?  Is PJM actively and independently monitoring MCRP's milestones, or are they simply taking FirstEnergy's word for it that its MCRP is on schedule and meeting milestones?  JCP&L's poor execution of this project has already cost the consumers three years of reduced reliability.  At what point will PJM "re-evaluate" the MCRP instead of simply shifting the milestones JCP&L fails to meet into the future?

While it is true that PJM has identified MCRP as the solution to future violations, that's only part of the story.  PJM can act to re-evaluate a failing project to come up with a better solution to prevent reliability violations.  PJM's mission is reliability, not adhering to rigid project concepts proposed by its members.  In fact, PJM transmission projects are suspended, canceled, or re-evaluated frequently.  PJM's approval of a certain project does not set its completion in stone.  PJM is subject to the outside forces of state regulators, who hold the ultimate authority to permit a certain project.  And state regulators are subject to the outside forces of state citizens who may support or oppose certain projects that are proposed.  The NJ BPU must weigh the benefits of the project against its detriments and find that the benefits outweigh the detriments.  If it does not find the MCRP beneficial, the NJ BPU may deny the project a permit.  And then it would be kicked back to PJM to come up with an alternative solution.  This sounds like a very long and expensive road, and ultimately it could cost JCP&L customers their reliable electric service. 

When will it be time for PJM to pull the plug on the MCRP?  Now, while there's still time to find an alternative solution to looming reliability violations?  Or later, when the lights go out?
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Offshore Wind Would Require Little New Transmission

2/24/2017

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A study released by the University of Delaware and Princeton University found that the east coast PJM grid can handle huge injections of offshore wind.
The UD and Princeton team showed conservatively that, with some upgrades to transmission lines but without any need for added storage, the PJM grid can handle over 35 gigawatts of offshore wind—that’s 35 billion watts—enough to power an estimated 10 million homes. They also found that the PJM grid could in the future handle twice that amount, up to 70 gigawatts, as wind forecasting improves, allowing the power operator to better predict and harness more wind.
That's really not surprising.  PJM has been looking at offshore wind for years.  What is new is the buy-in of eastern states to make it reality.

Coastal cities have a strong network of transmission that has been bringing them fossil fuel energy from the Ohio Valley for the past century.  The new report says that network should be upgraded to support reverse flow, that is from east to west, instead of west to east.  Sure sounds like a better plan than to build a new, expensive, gigantic network of transmission from the west to move an inferior terrestrial wind resource to the coastal cities.

And with the operation of the first offshore wind farm in Rhode Island well underway, eastern cities are also realizing the economic growth that comes with new industry.  A thriving offshore wind economy will breathe new life into eastern ports... where those receiving the benefits of the offshore energy will also receive the economic benefits of creating it in the first place.  It's a way for eastern cities to keep their energy dollars at home in their own communities.

Even with some minor transmission upgrades, the beneficiaries of the offshore wind transmission will also be those affected.  A plan to ship wind energy from the Midwest causes burden on Midwestern landowners who receive no benefit from the transmission, and this is what has delayed plans to build "clean" lines for the purposes of meeting some imagined eastern "need" for Midwest renewables.

Offshore wind is a win-win idea for eastern cities.  The only ones clinging to last decade's bright idea of shipping Midwestern renewables coast-to-coast are transmission builders, terrestrial wind companies, and Midwestern state governments who thought they saw a huge tax benefit from producing energy for export.  However, state tax benefits intended to encourage the building of energy for export have gone just a bit too far, as states like Oklahoma and Wyoming have had to roll back tax credits and impose new production taxes on wind generation in order to balance their budgets.  Becoming the "powerhouse" for other states isn't all it's cracked up to be.  The companies who own the energy infrastructure are the ones who end up with all the money, and the citizens are often left at the alter with broken economies and a wasted environment.

Every region has its own renewables, and developing local renewables is a much smarter choice than importing them from other regions.

We really don't need billions of dollars of new transmission lines to power the east coast with wind.  By using what's available locally, the east coast will make the switch to cleaner energy better, faster, and without requiring outlandish sacrifice from other regions to serve eastern needs.
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Clean Line Making its Ego GREAT again!

2/14/2017

5 Comments

 
We're going to build huge transmission lines!  It's going to be great!  It's going to be the greatest transmission build ever!  And we're going to make the American people pay for it in their monthly electric bills!  It's going to be GREAT!
Perhaps the new mantra is “we’re going to make transmission great again,” Skelly said.
Oh, puh-leeze.  Transmission is already great in this country.  In fact, we have federally regulated transmission planning and reliability organizations that plan and operate the greatest transmission system in the world.  These organizations carefully monitor our transmission system to ensure that it serves electric consumers reliably, economically, and meets public policy mandates.  It's already GREAT!

And the planning and reliability organizations have never found a need for thousands of miles of expensive, invasive "clean" lines.  That's why Clean Line Energy Partners is a merchant transmission company, proposing to build new transmission outside our regulated system and shoulder all the financial risk that nobody may find its lines useful, economic, or necessary to purchase.  We don't need Clean Line to "make transmission great again."  Our transmission system never stopped being great, but if it did, regulated planners would propose additions to the system to ensure it remained great.

But Clean Line needs our regulated transmission system to make itself great.  It needs volunteer customers to provide a revenue stream that would make its proposal profitable for its filthy rich investors.  And when that did not happen voluntarily, Clean Line now seeks to use the federal government to force electric customers into captivity to finance its projects.

Clean Line and its environmental sycophants, along with transmission industry profiteers, gathered together last week to scheme up a way to force legislators and governmental regulators to usurp state authority to site and permit new transmission projects.  And hilarity ensued.

Considering that there was only one news report of the event, and the front group that organized it didn't bother with social media engagement, it more closely resembled a closed echo chamber that nobody cares about.  So even though Clean Line president Michael Skelly shamelessly sucked up to the political party in power, nothing of any import happened.  Except I laughed!

Conference organizer "Americans for a Clean Energy Grid" has been trying to make itself relevant for years, but their execution is lame and conference attendees may randomly crap on all their ideas.
The organization, an initiative of the Energy Future Coalition, has held regional transmission conferences, but this was its first national event.

The coalition was formed in 2002 by former Sen. Tim Wirth, a Colorado Democrat; Republican C. Boyden Gray, who served as White House counsel to President George H.W. Bush; and Democrat John Podesta, a former aide to Presidents Bill Clinton and Barack Obama who chaired Hillary Clinton’s 2016 presidential campaign.
So this is really a political organization trying to masquerade as an industry or regulatory organization.  And even when they can manage to get important sounding participants to show up, the participants may not share the organization's rabid support for building new transmission outside current regulated planning processes.
“I’d love to have more load growth. It ain’t going to happen,” Craig Glazer, PJM’s vice president for federal government policy, told the gathering.

Weak load growth will make it more complicated to finance upgrades for aging transmission, and the lack of a federal carbon tax or renewable mandate is making it difficult to integrate renewable generation, Glazer said.
Gosh, that really doesn't sound like a glowing endorsement for building new merchant transmission to serve PJM consumers, which seems to be Clean Line's target market.

And when the organization's dream of taking away state authority to site and permit transmission was brought up:
Hoecker and Brown discussed FERC’s inability to gain “backstop” siting authority, saying it’s still very difficult to prevent individual states from blocking a project. The Energy Policy Act of 2015 amended the Federal Power Act to give FERC the authority to site electric transmission lines blocked by states, but court rulings have blocked the commission’s attempts to use it, prompting some in Congress to propose additional legislation strengthening FERC’s authority.

Brown said that Order 1000 hasn’t really helped SPP much with large regional projects.

“We need to decide what we want this grid of the future to look like,” Glazer said. For example, should it be a “localized grid” that can harness distributed generation? he asked. “There’s an added complication; it’s not even clear who is in charge,” Glazer said. FERC, state utility commissions and governors all have a say in siting decisions, he said.

If each governor is asked what infrastructure projects they want, the country will end up with a lot of state-based projects, not interstate ones, Clean Line Energy Partners President Mike Skelly said.

Perhaps the new mantra is “we’re going to make transmission great again,” Skelly said. The power to select infrastructure projects should not be taken away from transmission planners and placed in the hands of Congress, he said.

Skelly and others cautioned the Trump administration not to skimp on project reviews or stakeholder input. The key is that all projects must have “timelines” for regulatory approvals to avoid infinite delays, he said.

The executive director of the AFL-CIO’s Industrial Union Council, Brad Markell, said the labor movement agrees with the need for “hard timelines” to shorten the permit process.

Markell said that labor unions have been in contact with the Trump administration on potential infrastructure efforts.

“From our point of view, more power for the federal government and less power for the states [on electric infrastructure] would be a good thing,” he said.

Others deemed that unlikely. “I think we’re stuck with the system we have,” Glazer said.
But, wait a tick, the Skelly chameleon has actually participated in a federal process that skimped on technical project review and stakeholder input in order to usurp state siting authority for one of his "clean lines."  It seems to me that this is a top-down approach to forcing regulatory approval, instead of a fair and open review of proposed projects.

And then the environmental groups weighed in and things got a lot sillier.
Mary Anne Hitt, executive director of the Sierra Club’s Beyond Coal campaign, said that — contrary to what conference participants may have heard — her organization doesn’t oppose all power lines, only those that appear aimed to “prop up fossil fuels.”

The environmental group opposed the abandoned “coal by wire” Potomac-Appalachian Transmission Highline (PATH) project in PJM. On the other hand, it has backed the Plains and Eastern Clean Line Project, designed to move renewable energy from Oklahoma to Tennessee.

Hitt said she was concerned that President Trump’s nominee for EPA administrator, Scott Pruitt, opposed Clean Line in 2015 as Oklahoma attorney general.
Right... the Sierra Club should be the sole adjudicator of whether transmission projects "appear aimed to prop up fossil fuels."  And this subjective determination can really filter out bad projects.... I guess she doesn't know that her favorite Clean Line projects are being marketed as an arbitrage opportunity to ship fossil fueled electricity between regions, and that "clean" lines can't actually exist because all transmission is open access regardless of fuel source.  I guess that's what happens when you have a bunch of environmentalists meddling in things they don't really understand.

And an ineffectual time was had by all.  But, hey, the political posturing was exquisite!

And speaking of political posturing, here's some political posturing from E&E News regarding a real Washington, D.C., organizational conference with clout - the National Association of Regulatory Utility Commissioners winter meeting.  The members of this organization actually regulate utilities, they don't just talk about it.  E&E complains:
Curiously, there are no sessions scheduled there addressing the unsettled question of whether the federal government has any legitimate interest in transmission siting.
That's probably because this question is NOT "unsettled."  It's quite settled.  It's been settled for years.  Decades.  States have jurisdiction over electric transmission permitting and siting.  The federal Energy Policy Act of 2005 attempted to shift permitting to the Federal Energy Regulatory Commission if a state failed to act within one year on a permit for a project in a federally designated "national interest electric transmission corridor.  That has never happened, so who's to say its ineffective?  What was ineffective was a misinterpretation of this statute (Sec. 1221) that ended in a couple of hugely expensive federal court battles.  The EP Act also allows the U.S. DOE to "participate" in transmission projects financed by third parties, but reserves siting authority to the states.  Again, misinterpretation of the statute by the government has resulted in a federal court battle, still in progress.

This "question" isn't unsettled.  It's written in black and white.  But for those who want to misuse statute, it becomes an "unsettled question" kicked into federal court.  Just because an entity doesn't like the law does not make the law open to interpretation.  The law does not allow the federal government any authority over,  or interest in, transmission siting.  Transmission siting is state jurisdictional.

While it's oftentimes hard to tell a useful and influential Washington conference from a useless and ineffectual one, remember that not all Washington gatherings have the same amount of clout.
5 Comments

Dominion's Boogeyman Fails to Scare Tidewater

1/13/2017

0 Comments

 
Dominion upped the ante on its Surry-Skiffes Creek transmission project this week.  Because it has not been successful in overcoming opposition to an aerial crossing of the James River, it introduced the blackout boogeyman in the form of a remediation plan for the area, filed with regional grid operator PJM.
The so-called remedial action scheme Dominion prepared and presented this week to PJM Interconnection, the operator of the 13-state electrical grid Virginia is plugged into, would cut power to Hampton, two-thirds of Newport News, Poquoson and eastern York County if there are faults on two of the dozens of components in the Peninsula's high transmission network.
Oh no!  Blackouts, you say?

The people of the Tidewater said, "meh."
They say Dominion's been using scare tactics when it has said there could be as many as 80 days a year in which rolling blackouts are possible. Dominion says that's the number of days when demand is so heavy that faults in the system could force it to cut some customers off in order to avoid a widespread blackout.

"It appears that Dominion Virginia Power would rather continue their campaign to frighten consumers and threaten to close their Yorktown power plants," said James Zinn, a trustee with the Save the James Alliance, who argues that federal law allows the U.S. Department of Energy to order a power plant to operate in an emergency.
Well, gosh, PJM better get to altering its transmission plans in order to avoid emergency, because that's just not acceptable, and it doesn't appear that the opposition is going to fold on this one.
"If nothing else, this is consistent with their continued inflexibility to consider less intrusive alternatives for their construction of towers over the historic James River," he said.
So, what could they do instead?  Bury the line underwater?  Ya think?  Honestly, Dominion, you're behaving like a 5-year old.  "I'm gonna hold my breath until I die!"  Stop being a pimple on the ass of progress.
0 Comments

Pavlov's Energy Markets

12/6/2016

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What's the difference between a generator over-forecasting its output in order to collect DAMAP payments from MISO when their day-ahead schedule is higher than their actual real-time output, and an electricity market trader making trades designed to collect MLSA transmission credit payments from PJM?

It sure looks like it's based on pre-conceived notions of the "goodness" of the recipient of the regional transmission organization payments.

A recent article in RTO Insider details a report to MISO's market subcommittee by Market Monitor David Patton, which revealed "
some wind generators appear to be deliberately over-forecasting their output to inflate their revenues."
Two-thirds of MISO’s $7.5 million in DAMAP payments to wind resources in 2015 and 2016 was because of over-forecasting and only $2.5 million was spent on curtailment, Patton said. “Most of our wind DAMAP payments are unjustified,” he said.
DAMAP payments are described like this:
The purpose of DAMAP is to provide an incentive for Market Participants to be flexible in their offers in the real-time market.

The DAMAP compensates suppliers when (i) the real-time dispatch of a resource is reduced below the day-ahead schedule's level, and (ii) the market participant would have been financially better off in real-time had it operated at its day-ahead schedule.

Read the whole article for an explanation of how DAMAP can and is being manipulated by wind generators to receive higher compensation payments. 

This is complicated stuff!  Regional energy markets are extremely complicated, to the point that they are nearly incomprehensible to the regular folks who fund millions of dollars in "market compensation" payments every year in their electric bills.  But don't feel too bad, it appears that energy markets are also complicated for the experts who create and police them to try to prevent manipulation by traders and other participants.  Every regional electric market would be well-served by a couple of whip-smart analysts whose only job is to continually test the market by attempting to find ways to manipulate it for profit.  Obviously the creators and monitors of these markets are completely blind to the opportunities they create that allow participants to unwittingly "push the money button" and be rewarded by compensation payments.  To expect Pavlov's dogs to immediately report the unexpected reward they received, instead of continuing to push the button and feast at will, is unnatural.  If the creators and monitors of energy markets expect an unnatural response, they need to provide a compensatory reward for it.  In lieu of having staff dedicated to and capable of rooting out flaws, market monitors should look at providing the stimulus necessary to find volunteers within the market participants.

So, how did the MISO Market Monitor propose to solve this problem, once discovered?  He proposed changes to the market, instead of punishing the wind energy dogs who had been pushing the money button that brought it to his attention.  He chose to stop ringing the bell.

But how did the PJM Market Monitor propose to solve a similar "money button" problem that developed in his own market?  He worked with FERC to punish the traders who pushed the button and brought it to his attention.  He beat the dog.  In fact, FERC has proposed fining the traders somewhere in the neighborhood of $35M.

Why the disparate treatment?  Is it because the general public looks disparagingly upon "Wall Street" (and therefore traders big and small) as the root of all evil?  Is it because wind energy is looked upon by the same public as a "clean" and "good" struggling industry?  I've got news for you, general public.  Big wind is a hugely profitable industry whose greed knows no bounds!  What may have started out as a cottage industry predicated upon selfless environmental gains has morphed into a gigantic subsidy- and compensation-gobbling monster that fills the pockets of foreign investors with your gold.  Years of environmental propaganda has conditioned you to behave just like Pavlov's dogs when you hear the words "clean energy."  You may believe anything with a "green" label must be "good" and therefore more valuable, without examining any actual benefits to you.

Energy markets will only work if they are consistent.  Allowing one group of participants to escape the punishment heaped upon another group isn't consistent.  What kind of bell are they trying to ring?

Oh, and big wind is ripping you off... big time!
0 Comments

Constructability Calamities

8/10/2016

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Who comes up with the "constructability" summaries for PJM's transmission projects?  Do they hire a professional blackjack player to study the odds of approved projects pissing off the wrong people?  Where's the surety in spinning the wheel to determine whether a project is "problematic," when actual results depend entirely on circumstances beyond PJM's control?  The human factor is going to get them every time.

So, PJM's eternal Artificial Island project has been "suspended."  It's ever-changing scope and price tag have affected its "constructability."  The states of Maryland and Delaware were outraged that PJM's cost allocation assigned the majority of the project's costs to them, when they would receive little benefit.  "Suck it up, buttercup, we'll do better next time," said PJM.

Oddly enough, PJM's suspension of Artificial Island didn't even mention the cost allocation issue.  But nevertheless, the states are claiming victory.

Lesson:  With enough opposition, even PJM can change its mind.  And as the Delaware Public Advocate reminded PJM, this isn't the first time.
The DPA is not asking PJM to do something it has never done before. PJM has reevaluated
projects in the past. After reconsideration, PJM canceled the Mid-Atlantic Power Pathway ("MAPP") and the Pennsylvania-Allegheny Transmission Highway ("PATH") projects.

While the reasons for cancellation may be different in this case, the fact of the matter is that simply because PJM has approved a project does not mean that it gets done come what may. In cancelling the MAPP and PATH projects, PJM acknowledged that changed circumstances had caused it to reevaluate the projects; unfortunately, however, ratepayers are paying significant abandonment costs. We ask PJM to re-evaluate this Project before LS Power and PSE&G incur costs that will ultimately be recovered from ratepayers of all PJM members.

The DPA asks PJM to remember that end-use customers are ultimately the ones that pay
for projects such as this. Indeed, neither PJM nor its member companies would exist if not for customers. And those customers are not a wallet from which PJM and its member utilities can obtain unlimited funds.

Stop making poor "constructability" choices, PJM!

Speaking of... PJM approved a bunch of new projects yesterday.  Among them is a scheme to construct two new greenfield transmission projects across the Maryland/Pennsylvania border.
Picture
Sorry, but the PJM-supplied project map really is that crappy and devoid of recognizable locations.  PJM's world revolves around a map of substations and transmission lines.  Ringgold is really a place though, so that narrows down the approximate location of the western line.  Furnace Run is a town in western Pennsylvania, but the eastern line on this map begins south of York and Lancaster and probably ends somewhere near Towson, Maryland.  But don't worry about the lack of any recognizable places, because PJM's constructability summary has determined this project "is located on undeveloped land" and therefore the only likely obstacles may be bats, acquiring easements on Pennsylvania state land, and a few permitting hurdles.  No human factors acknowledged.

But I'm pretty sure people own that "undeveloped land," and those people probably will mind having a transmission line constructed on their property.  What remains to be seen is how big a squawk they can make about it.  Because, as PJM has demonstrated numerous times already, its planning isn't infallible, and when approved projects run into a buzzsaw of opposition, PJM has no choice but to go back to the drawing board and come up with a better project.

1 Comment

An Infographic of PJM Ineptitude

7/15/2016

6 Comments

 
Who is PJM?
PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of wholesale electricity in all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia.

Acting as a neutral, independent party, PJM operates a competitive wholesale electricity market and manages the high-voltage electricity grid to ensure reliability for more than 61 million people.

PJM’s long-term regional planning process provides a broad, interstate perspective that identifies the most effective and cost-efficient improvements to the grid to ensure reliability and economic benefits on a system wide basis.

An independent Board oversees PJM’s activities. Effective governance and a collaborative stakeholder process help PJM achieve its vision: “To be the electric industry leader – today and tomorrow – in reliable operations, efficient wholesale markets, and infrastructure development.”
We're all depending on these guys to keep the lights on and operate an electric market.  And that requires a lot of advanced mathematics.

Infographics tell a story.  They are graphic visual representations of information, data or knowledge intended to present information quickly and clearly. They can improve cognition by utilizing graphics to enhance the human visual system's ability to see patterns and trends.

This helpful infographic is prominently displayed in PJM's lobby, ostensibly to inspire visitors to think about how PJM's hard work to manage electricity supports everyone's creature comforts.  It's an attempt to "dumb down" electricity to make its awesome power easily understandable and relevant to the hoi polloi who shuffle daily between PJM's conference rooms and tasty M&M bar.  PJM has lots of important visitors to impress!  So, grab a handful of M&Ms (plain or peanut!) and wander through the infographic gallery for a snacking good time!
Picture
Except it looks like PJM took the "dumbing down" a little too seriously and ended up with just plain dumb.

What can one megawatt hour of electricity do?

It can power:

600 Super Bowl parties (300 kWh)
5,556 iPhone charges (100 kWh)
Power a traffic signal for 3 months (200 kWh)
1,200 pots of coffee (100 kWh)
Download 133,320 songs (50 kWh)
Cool a refrigerator for 3 months (150 kWh)

The infographic informs that one megawatt hour (MWh) equals 1,000 kilowatt hours (kWh). 

What does all that add up to?

It's not 1 MWh.

It's 900 kWh.

Go ahead, add it up.  You probably won't even need one of those nifty scientific calculators PJM probably uses to manage the electric grid.  Any second grader can do it.

But PJM can't.

C'mon, PJM, less free nachos and danish on the snack bar and more math that we can rely on!

Perhaps PJM's mathematicians consider this infographic saved by the tiny disclaimer on the bottom?
Based on a variety of sources.  Numbers are estimations and may be rounded.
Rounded to the nearest thousand?  Is that the kind of magic math PJM uses to manage the electric grid?

I'm frightened.

If that infographic is intended to impress me with your electric grid prowess, you've failed.  Miserably.

So, now the fun begins!  How many blog readers that visit PJM regularly can find this infographic in the lobby and photograph it before it's removed?  How many visitors can snap a photo of the empty space left behind after its removal?  How many visitors can snap a photo of its eventual replacement (and fact check that one)?  How many visitors can inspire PJM to institute a "no photographs in the lobby" policy to save it from further embarrassment?

Be sure to help yourself to a complimentary snack while you're there.  Maybe the missing 100 kWh is powering the M&M dispenser?
6 Comments
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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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