FirstEnergy's union workers have sent a letter to Federal Energy Regulatory Commissioners asking that the agency's Office of Enforcement initiate an investigation into FirstEnergy's gaming of coal plant closures.

The union states that "...the retirements may also have a detrimental effect on energy, capacity and ancillary prices in the PJM Regional Transmission Organization (PJM)."

The union further reasons: 

"We are concerned that prematurely retiring such a large amount of apparently economic generating
capacity could lead to an increase in energy, capacity and ancillary service prices, to the benefit of FE's remaining facilities."

"This concern is heightened by FE's failure to explain adequately the bases for its plans.  With nearly two years remaining before the MATS closure deadline, FE's decision not to invest in MATS compliance fails to justify its evident rush to deactivate the plants. The decision is
likewise not explainable as the consequence of  "continued low market price(s] for electricity."  While the 2013 PJM capacity auction resulted in relatively lower prices (and a decline in the amount of coal-fired  generation clearing the auction), those results apply to the period 2016-2017, which is after the April 2015 MATS compliance deadline. FE has not shown that
either plant is losing money, nor are we aware of any efforts to sell the plants.  In these circumstances, a premature closing of the units may constitute a form of physical withholding and an improper effort to affect market prices."

In addition to being concerned about its own members, the union says, "...consumers deserve assurance that FE's action will not harm reliability or artificially inflate energy and capacity prices in PJM."

They wrap up:

"We urge the Commission to investigate FE's actions. In particular, the Commission should investigate FE's internally-stated reasons for the proposed closure date and any related business studies and cost-benefit analyses. Such an investigation would be in the public interest, consistent with the Commission's anti-market manipulation and rate regulatory authority, and in
the interest of the communities affected by FE's action."

Why, sure, I'd love to see those studies and analyses, too.  How about it FE, want to share?

Chances of FERC acting on this?  Slim to none.  FE's plant closure market manipulation must be perfectly legal because those minding the store continue to allow it to happen unfettered.   Of course it's going to artificially inflate energy and capacity prices that consumers must pay and create profits for the flailing FirstEnegy financials.  That's what this game is all about!

Even rats know when to abandon a sinking ship.  These guys should start looking for other jobs.  I'd like to see Tony the Trickster keep just one plant running with the help of his million dollar henchmen and a couple of cute cocktail waitresses.  Got candles?

Wow, what a shocker!  FirstEnergy's grid monkey, PJM Interconnection, has determined that the two coal-fired power plants the company recently announced for closure in October are necessary for reliability.  In order to keep the plants open until FirstEnergy can further add to its corporate coffers by making transmission upgrades to take the place of these two generators, PJM will offer the company what's known as reliability must run (RMR) contracts.  RMR contracts provide a big pay day for FirstEnergy in exchange for extending the closing date of Hatfield's Ferry and Mitchell and keeping the plants available to ensure reliability.  And, like every other dime PJM spends, the money for the RMR contracts is added to your electric bill.  How long will this last, how much will it cost consumers, and how much will FirstEnergy profit from its plant closure game?  Nobody knows.

PJM is an industry-run cartel.  How else can companies like FirstEnergy continue to play the same game over and over and get away with it?  According to PJM's rules, a generator must only give 90 days notice that it will close.  Can PJM build a replacement generator or make necessary transmission upgrades in 90 days?  Of course not.  Did this rule ever make any sense, or was it specifically set up to be gamed in this fashion and produce unearned profit for PJM utilities?  The only way you can prevent being gamed this way is to build your own generator by installing solar or another renewable resource on your home or business.

FirstEnergy's decision to close these plants, followed by a subsequent decision to keep them open indefinitely isn't fair to its workers either.  Closing the plants on short notice without providing a transition plan for the employees is bad enough, but now FirstEnergy prolongs their agony by dragging it out.  Maybe the company should use this reprieve to help their employees find or train for new jobs, but they won't.  FirstEnergy simply doesn't care.  Will FirstEnergy share its RMR windfall with these displaced workers to ease their transition to new jobs? Of course not, that extra money goes in Tony's pocket!  Workers are expendable to companies like FirstEnergy.

The only thing missing from this round of the FirstEnergy Plant Closure game so far is an artificial generation shortage that drives up capacity prices in the region.  Shall we expect that to happen at the next auction? 

How does this keep happening?  PJM and its silly rules and "markets" don't save you any money.

The PJM cartel likes to pat the stray consumer who ventures into its lair on the head and pretend that they are "stakeholders" who matter. Go ahead, pull up a chair, little consumer, our cartel is transparently open to all... except when its not.

The PJM cartel is a private club meant for the MWM (Members Who Matter - thanks, Bill!).  The rest of you "stakeholders" only have a role in ensuring that PJM's annual budget of $32M is adequately funded.  Other than that, PJM really doesn't care what you think.

Now, imagine the shock and horror of one bourgeois "stakeholder" who received the following email invitation to participate in PJM's Stakeholder Survey yesterday.

The funny part here is that the recipient of this email hasn't paid PJM one whit of attention for several years, has no clue what "organization" he is supposed to be representing, or how PJM even got his name and email address.  That's right, PJM, you managed to send your survey invitation to a common ratepayer!

They weren't lying about this survey taking 20 - 30 minutes.  It's quite extensive and if you've used any of PJM's "services" over the past year, it can expand endlessly like a window, inside a window, inside a window, ad finem.  But, it's the best look us plebeians are going to get at what the cartel club considers important.  Like royalty everywhere, PJM just doesn't realize how arrogant they come across.  Here are a select few survey questions:

PJM wants to know about its "corporate reputation" and how you would rate them on the following:

Being well-managed, trustworthy, innovative, an industry leader, attracting and retaining the best and brightest employees, having efficient processes, having required systems and infrastructure in place AND the most important:

Helping my company succeed and being easy to do business with, because the PJM cartel's first mission is to help its members make money!  What?  You thought PJM's mission was to keep the lights on?  Ha ha ha, you little prole, what a kidder!

PJM also wants to know how well they've done educating stakeholders and helping members work toward consensus of stakeholder issues. 

PJM also wants your opinion on their food and "making you feel valued."  What is this, a Chuck E. Cheese franchise, or a regional grid operator?  Who knew PJM was a vacation destination?

PJM also wants to know where you get your information about them (because propaganda is only useful if it is disseminated correctly): 
Inside Lines, committee emails, communication with PJM employees (ultra-secret meetings where unneeded transmission projects are propped up endlessly), communication with committee members, trade media, pjm.com, or a company representative.

PJM asks:  Have you read, seen or heard anything in the news media about PJM in the last six months? (In other words, are you Amish?)

What sources do you find useful for providing industry info.? (because PJM needs to make sure their propaganda reaches these markets):

Internet search engines such as Google or Bing, Industry-specific blogs, Internet news sites such as CNN.com, Blogs and/or online discussion groups, Twitter, Facebook, RSS feeds, YouTube or trade media, newsletters or news media.  For any you checked, be sure to now check them off your list of reliable sources in the future.

Perhaps PJM doesn't have the right kind of role model in Mother FERC, but the purpose of an RTO is supposed to be to ensure open access and non-discriminatory transmission services, the continued reliability of the system, and to operate wholesale electricity markets that provide electricity suppliers with more options for meeting consumer needs for power at the lowest possible cost.

It's really not all about providing a smokescreen for investor owned utility transmission building schemes, wining and dining utility executives, or helping investor owned utilities to succeed.  It's supposed to be about serving the electric consumer, or "stakeholder." 

Here's how PJM might go about doing a real "stakeholder" survey:  The following question, and a mechanism for every one of PJM's 60 million "stakeholders" to individually answer it, should be featured on every cable news channel and on the front page of USA Today:

Have you ever heard of PJM Interconnection and how it serves consumers?

The entities that stand to profit from building hundreds of billions of dollars worth of new high voltage electric transmission are at it again.  In the wake of FERC’s Order 1000 requiring cost allocation to be “at least roughly commensurate with estimated benefits,” and that those who receive no benefit shall not be allocated costs involuntarily, the industry has simply redefined the term “benefit” to suit their pecuniary purposes while toeing the line with FERC.  This is exactly what my Magic 8 Ball told me would happen, so we shouldn’t be surprised.

WIRES, which is a group of industry lobbyists and their sycophants, has bought a study prepared by The Brattle Group (proud industry whore since 1990) that supposedly identifies and analyzes a whole bunch of “new” benefits of building transmission that they feel will, when added to current planning evaluations, ensure that transmission wins every time!  *cha-ching $$$$* WIRES pretends that it is only concerned about the good of society.  Baloney.  It’s all about the money!

WIRES and their well-paid former FERC Commissioner counsel have submitted this study to FERC because, “It is our expectation that this new analysis will be helpful to the Commission and to parties filing in compliance with the regional and interregional planning provisions of Order No. 1000.  Although Order No. 1000 compliance involves numerous additional dockets, we believe the report should at least be part of the record in the overarching rulemaking proceeding so that parties are able to access and use its contents.” 

Right, let’s allow WIRES buy some new FERC policy with our money.  You know how I know this report is made-up crap?  Because it uses sources such as Clean Line Energy Partners’ self-serving analyses and other industry-commissioned “studies,” as well as clueless NYT blogger Matt Wald and other biased media sources.  Any trained monkey can compile a whole bunch of dubious sources to come to pre-determined conclusions.   Congratulations, Brattle Group!  I wonder how much they charged WIRES for something a 3rd grader could have accomplished?

So, how speculative are all these new “benefits” that transmission planners must consider in order to force unneeded transmission?

WIRES says, “An analysis that ignores or rejects benefits that are not measured with precision implicitly assumes that the value of such benefits is zero. This will systematically understate the overall value of transmission investments.  It will also, in turn, lead to the unintended consequence of rejecting valuable transmission projects that offer a broad set of long-term benefits with total values that exceed project costs.”

Or, perhaps there’s a reason these “benefits” have historically been given a value of zero in order to ensure that only cost-effective and needed transmission projects are actually built?

Here are the “benefits” that WIRES insists be calculated, no matter how specious they may be:

1. Production cost savings;
2. Reliability and resource adequacy benefits;
3. Generation capacity cost savings;
4. Market benefits, such as improved competition and market liquidity;
5. Environmental benefits;
6. Public policy benefits; employment and economic development benefits; and
7. Other project-specific benefits such as storm hardening, increased load serving capability, synergies with future transmission projects, increased fuel diversity and resource planning flexibility, increased wheeling revenues, increased transmission rights and customer congestion-hedging value, and HVDC operational benefits.

Production cost savings are one of the traditional ways transmission “benefits” are derived.  However, “As noted earlier, production cost savings only measure the reduction in variable production costs, including fuel, variable O&M costs, and emission costs.  This means that production cost savings, even if the simulations capture the additional factors discussed above, will not capture the benefits associated with reliability, capital costs, increased competition, certain environmental benefits and other public policy benefits, or economic development benefits. These benefits provide additional value to electricity customers and to the economy as a whole.”

WIRES would rather have us concentrate on those hard to quantify “economy-wide benefits” that can be concocted out of whole cloth and come in handy to tip the scales in favor of questionable projects.  In addition, WIRES recommends that regions bundle a whole bunch of such dubious projects into “project portfolios” (as MISO has done).  When “benefits” of many projects are combined into an impossible to separate mega-project for regional transmission organization approval, WIRES believes this sleight-of-hand spread of “benefits” among a wider pool of consumers makes cost allocation easier. 

“We also suggest aggregating beneficial transmission projects into larger portfolios of projects to simplify the necessary cost allocation analyses, reduce misperceptions that benefits appear to accrue only to a limited subset of market participants, and facilitate less contentious cost allocation processes.”

And although the report fails to mention it, this combination of many small projects, owned by many different entities, into one big mega-project also allows for convenient re-separation of each smaller segment in order to sail through state or local approvals while shepherded by incumbent utilities that have developed relationships with communities, legislators and regulators.

Here are a couple of spurious gems from the WIRES “report” that had me snorting with laughter.  Do they actually think that intelligent people will fall for this dreck?

“For example, transmission lines that allow for increased imports of lower-cost generation from a neighboring region can provide benefits to both regions: the importing region through a lower cost of delivered power [to consumers] and the exporting region through increased revenues to the exporting suppliers. The increased export revenue can also be a benefit to electricity customers in the exporting region if these additional revenues are used to offset the cost of regulated generation assets or if wheeling out the revenues paid by exporting merchant generators can be used to offset the exporting region’s transmission revenue requirements.”

That’s right… new transmission simply levelizes electricity prices between regions.  While the importing region gets the benefit of lower electricity prices, the exporting region gets the “benefit” of higher electricity prices PLUS a share of the cost of the transmission project that raised their electric rates.  What a bargain!  All benefits to an exporting region go right into the coffers of generation companies.  And here’s a perfect example from the report:

“The economy-wide benefit of the deferred generation investments was estimated at $320 million, about half of which was estimated to accrue to customers in Texas, with the other half of the benefit to accrue to merchant generators in Louisiana and Arkansas.” 

Building transmission to import renewables from coast-to-coast is not economic, and when given a choice between high-priced renewables or affordable "dirty power" utility bills, consumers overwhelmingly vote with their wallet.  In spite of also being motivated by its collective wallet, WIRES just doesn’t get it:

“In such cases, despite the fact that both transmission and retail electricity rates may increase, the transmission investment can reduce the overall cost of satisfying public policy goals.”

Sometimes, new transmission has unintended effects.  Perhaps our Pollyanna environmental warrior friends, who are backing transmission expansion that they optimistically believe will result in renewable energy super-highways, should take a lesson:

“Similarly, the CREZ projects in Texas have also provided new opportunities for fossil generation plants to be located away from densely populated load centers where it may be difficult to find suitable sites for new generation facilities, where environmental limitations prevent the development of new plants, or where developing such generation is significantly more costly.”

In addition, new transmission can perpetuate environmental and social injustice whereby the poor and politically under-represented continue to bear a disproportionate share of the burden to supply the needs of the rich and politically connected in their own or other regions.

WIRES tried to give their dubious “report” more credibility by having it peer reviewed.  Despite being able to choose its reviewers and having sole power to approve or disapprove the content of the review, WIRES still couldn’t prevent a little sanity from sneaking in at the end of the report.  The peer reviewers opined: 

“The electric power system is a complex, interconnected whole. While the interconnection may be argued to be the transmission system, the whole incorporates generation (both central and distributed), storage (again central and potentially distributed), distribution in all of its complexity, and the interaction with end users at all levels and at all levels of complexity in use and control.

It is difficult, if not impossible, to fully evaluate the benefits of transmission without reaching into the competing benefits of investments in other sub-systems of the power system. Technology is not standing still in terms of the transmission system or in terms of the other sub-systems of the power system. Two examples of changes whose impacts upon asset growth in transmission have yet to be quantified are:

• The impact of significant investment in distributed generation and potentially storage within the distribution system. These changes are being brought about by public policy decisions combined with a dramatic expansion in communications and controls allowing for the development of distributed energy systems that interact with the larger utility system

• The impact of sensing and control of the transmission system that allows for dynamic reconfiguration of the topology of the transmission system. Often referred
to as “line switching,” the benefits have been known by system operators for decades. It is only with increased monitoring, advances in analytic techniques, and computation speed that these concepts can be brought into the operational time frame.

Technological changes are adding points of pressure to the power system in general and specifically to the transmission sub-system as the interchange network that allows the system to remain balanced.”

While WIRES is trying to hurry along the filling of its members’ pockets, the electric utility industry is undergoing a sea change that’s going to make most of this new transmission obsolete before it becomes used and useful.  But these guys don’t care if a huge investment in unneeded transmission is left for their grandchildren to repay, as long as the money comes rolling in today.

If we’re going to make up a whole bunch of new transmission “benefits” that must be considered in any regional planning cost-benefit analysis, how about if we also now consider the true cost of building new transmission?  WIRES thinks that the true cost of building transmission is contained in the annual transmission revenue requirement of any particular project.  However, that does not consider the true costs to communities, individuals, landowners, ratepayers, or society as a whole.  But where are we going to get the money to hire an industry whore economist to make up a bunch of crap like WIRES did?  Oh, not to worry… the way transmission opposition is expanding lately, it’s only a matter of time before some transmission routing doofus uses his etch-a-sketch to draw a line through the backyard of an economist or two (or maybe that’s already happened, or maybe the opposition leadership is quite capable of preparing their own cost-effective analysis and report -- The Costs of Electric Transmission: Identifying and Analyzing the True Cost of Transmission!)  If you want to be part of our brain trust and help us identify the true cost of new transmission, just let me know!

Electric market manipulation is becoming mainstream news lately.  In the comments section of my post about renewal of the PJM Market Monitor's contract this week, manipulative banksters JP Morgan and Barclays were mentioned.  Just to be clear, JP Morgan and Barclays have been accused of manipulating electricity markets in California, other western markets, and midwest states.  They have not been accused of manipulation in PJM (at least not in these big, high profile cases).  Is that a good thing or a bad thing?  Does it mean that these banksters haven't been playing games and skimming on PJM's electricity market, or does it simply mean that they haven't been caught yet?

The Wall Street Journal had a big, splashy article about market manipulation the other day.  It's got some really great graphics that explain one way that these banksters have manipulated the market in such simple terms that anyone can understand it.  Bankster offers electricity in the next day market at a really low price, then jacks up the price when it comes time to actually sell it.  The buyer decides not to buy it after all, because it's too expensive.  Bankster collects what's known as a "make-whole payment" from the buyer in exchange for being ready to supply power.

Maybe the WSJ's graphic designer needs to go work for FERC or Monitoring Analytics to make their reports and explanations of market manipulation sexy enough for water cooler chat, too.

Here's FERC's attempt to be scary with talk about fraud and attempts to deceive.  Any ordinary consumer reading this would still have no idea what market manipulation really is.

Here's the PJM Market Monitor's 2012 State of the Market Report.  Boring!  You'd have to be a real geek to even enjoy flipping through it.  But wait, Monitoring Analytics has produced a "Press Briefing" version that includes some explanation of what they do and what happened in 2012 as represented by a bunch of graphs!

Where's the comic book version?

There isn't one.  Therefore, if it wasn't for our friendly, neighborhood banksters, we wouldn't even be discussing market manipulation in the first place.  And market monitors and regulators wouldn't be today's pop culture rock stars.  And try though they may, FERC and Monitoring Analytics seem to be incapable of dumbing this stuff down enough so that the average consumer can understand it, much less find it interesting.

The WSJ article explains one scheme that was uncovered.  There are probably hundreds more going on right now, and hundreds more being devised.  As soon as the regulators close one loophole, the banksters start manipulating another.  It's a never-ending battle.

Deregulation and competitive markets don't benefit consumers.  It actually costs them money.

Meet the new boss, same as the old boss.

PJM and Monitoring Analytics signed a new contract the other day.  After a bit of a kerfuffle earlier this year where the PJM Board of Managers sought to issue an RFP to evaluate other proposals to provide market monitoring services for PJM, it appears that not much has changed after all.

There's a new "Protocol for Improved Interaction" where PJM and the Market Monitor promise to play nice and share their deepest, darkest secrets.  It looks like each party had to promise to make an increased effort to keep the other better informed, to include:

"The MMU will notify PJM (Andy Ott) in writing (through email) when it becomes concerned with specific market participant behavior which creates major issues for the PJM markets."

That should be really helpful so that the entities playing market games can be given one last warning so they can fire up the shredder before they get caught.

Let's face it, fellow consumers, we will never understand the Market Monitor's function, no matter how many unread copies of the State of the Market Report are riding around in our back seats.  It's all a matter of blind trust.

The arrogant energy industry and their paid media pimps continually pretend they know what consumers want.  They believe that if they write and publish enough lies that consumers will start to believe them.

Not.

Forbes "contributor" Ken Silverstein tells us that "Utilities would have an easier time building transmission lines if it were not for a feisty public, which generally feels that those ugly lines ought to be built somewhere else."

Really?  This guys bills himself as "editor-in-chief for Energy Central's EnergyBiz Insider. With a background in economics and public policy, I've spent two decades writing about the issues that touch the energy and financial sectors. My EnergyBiz column has twice been named Best Online Column by two different media organizations."  However, his NIMBY name calling merely showcases his complete ignorance of the dynamics of current transmission policy debate.  Is he really this clueless, or is he merely posturing for the crowd to parrot power company propaganda?

Let's take a look at just a few of the facts Silverstein gets wrong:

1.    "...the transmission grid is aging and it needs to be updated and expanded so that it can fulfill the needs of consumers — many of whom don’t want those unsightly lines near them."

WRONG!  The transmission grid was not designed to wheel energy from coast to coast to fill the pockets of greedy traders.  The industry is not spending enough capital "upgrading" for any real need, but has been banging its head against a brick wall attempting to "expand."  Let's look at just one example:  While PATH was shooting blanks attempting to get its new build project approved, Dominion slipped in and quietly punked AEP/FirstEnergy with the rebuild of an existing line that completely obviated the PATH project.

Consumer issues center on NEED and COST.  It's not about NIMBY anymore.  How loud do you suppose Silverstein would squeal if someone routed a transmission line through his own backyard?  Silverstein loves new transmission... as long as there's no personal sacrifice on his part involved and it's not in his backyard, therefore, Silverstein is the real NIMBY.

2.    "Inevitably, disputes emerge that typically center on the potential ecological harm that a given line may take. In other instances, the arguments are that the development is occurring in states that will not get the benefit of the added electricity, or that it would increase the usage of coal.

Such was the case when American Electric Power and FirstEnergy Corp. tried to build the so-called Potomac Appalachian Transmission High-Line, which would have stretched 275 miles from West Virginia into Maryland. The PJM Interconnection, which coordinates the transmission planning for the MidAtlantic states, has now withdrawn the project. It has done the same for Pepco Holding’s Mid-Atlantic Power Pathway, although both concepts could get resurrected once the economy is in full swing."

WRONG!  PJM cancelled the PATH project because it was not needed, not because of cost allocation, environmental or coal-related issues.  The opposition to PATH was ALWAYS based on the fact that the project was not needed. 

PATH and MAPP are not going to be "resurrected," and neither is an energy-wasting economy that increases energy demand.  Consumers in the PJM region are already on the hook for the quarter billion dollars wasted developing the unneeded PATH project, a project that will never provide consumers with any benefits.  None.  Zero.  PATH and MAPP were part of an industry money-making scheme named Project Mountaineer and were never needed for reliability or market efficiency.

3.    "While the concerns and the subsequent legal battles are well intended, they oftentimes perpetuate uncertainty. That is, investors are skeptical because they can make more money in alternative investments while the delays impede reliability. And if brownouts or rolling blackouts occur, the financial toll can mount."

WRONG! Brownouts and blackouts?  I haven't heard that kind of fear-mongering since PATH got shelved.  Get a grip, Silverstein.  You and I both know that is NEVER GOING TO HAPPEN.  Silverstein goes on about new transmission needed for renewables and then tosses in the blackouts invective?  Sorry, but the lights will not go out if renewables can't be transported coast-to-coast. 

Investors are salivating at the prospect of plunking their dollars into transmission investments making double-digit returns, despite the industry's "the sky is falling" whining.  As well, transmission projects can and do request formula rates and incentives that provide them with a continual return during the development and construction period.  There's absolutely no risk to transmission investors.  None.  Zero. 

Maybe Silverstein should do some research before he approaches a keyboard in the future.  There's plenty of information to be had on this website.  Maybe Silverstein could learn a few things about his topic here?  And maybe, just maybe, he might want to consult a consumer before writing more folderol about what they want.

I received a great, big dose of hope for the future while hosting a MIT grad student doing research for her dissertation on energy markets over the past 4 days.  It's nice to know that the lights in my nursing home may stay on after all!

With the utility industry facing a big problem with an aging workforce that is not being replenished, its nice to know that the next generation of energy professionals are going to bring fresh, new ideas to the 100 year old utility business model.

Out with the old, in with the new!

Here we are melting during a cookout/party last night where Canay got to meet the folks who made StopPATH happen and talk with them about just what it is that consumers want.  It was 97 degrees in the shade, and about 150 degrees standing over the grill.  We all felt fortunate that Potomac Edison kept the air conditioner running.  I've never had so much help in the kitchen cleaning up from a party on the patio!

The smartly renamed RTO Insider brings us word of a new feeding frenzy that has erupted at PJM: 

Ever seen one of those TV clips where sharks go berserk feeding on the incapacitated corpse of a helpless animal?  The similarities are stunning.  Transmission builders are hungry, hungry, hungry for new projects where they can plunk down their "transmission spend" and spin the Wheel of Regional Cost Allocation and Incentive Returns to win big!

RTO Insider provides a run down of the proposals and a link to the July 10 PJM TEAC slide deck with more details and maps of each proposal (beginning on page 61).  I'm loving the way that RTO Insider makes the job of babysitting PJM so much easier for me!  No more random, inconvenient urges to go wade through PJM's webmaze to see what's new, and then going through all the trouble of running my find through the geek translator.  RTO Insider does all that for you!  Go get yourself a subscription now... because if you don't, I may know something you don't.

According to the RTO Insider's proposal list, all the proposals for Artificial Island include new transmission lines of various sizes.

It's just colorful lines on a map right now, isn't it?  It looks like someone at PJM had fun with their mouse and an RGB color chart, drawing proposed transmission lines across Maryland, Delaware and New Jersey.

Reality Check:  Each one of those lines runs through hundreds or thousands of backyards.  Real people, real property, real lives.  Will PJM spend any time contemplating the people whose way of life they are blithely sacrificing for the needs of others?  Will PJM consider the likelihood of opposition, environmental considerations, land values, or the welfare of affected individuals when choosing the winning proposal?  Will PJM notify the affected communities that there is a problem that needs to be solved by building new transmission lines in their area?  Will PJM consult with the communities to allow those possibly affected by the new project to weigh in on the proposal that is selected?

Of course not!  What do you think this is, a transparent democracy?  PJM will make its selection based on cost, or engineering, or other considerations (like which transmission company schmoozes best).  And then the winning bidder will begin planning their project and greasing the proper palms, carefully keeping their plans under wraps until they are ready to pull the rip cord and hold their public "open houses."  At that point, the transmission owner tells the people that the mysterious, unseen, regional transmission authority has ordered the company to build this project across the peoples' land and that there's nothing the transmission owner or the people can do about it.  The transmission owner's hands are tied and the peoples' fate is sealed!  What a load of crap!

These front-loaded fait accompli approaches never work.  The people will always want to backtrack to where the decision to build the transmission line was made in the first place.  They want to determine for themselves that there truly is no other option.  Meanwhile, the transmission owner pours buckets of ratepayer cash into astroturf front groups, dishonest TV commercials, smarmy land agents, political palm greasing, and celebrity spokeswhores, trying to convince the people, and ultimately the state regulators, that the project really is needed. 

There's got to be a better way.

Good luck with that, PJM.

Residents of Maryland, Delaware and New Jersey -- we'll get to know each other real soon, won't we?  *sigh*

On July 3, the Federal Energy Regulatory Commission dismissed a complaint brought by Wisconsin-based citizen/consumer groups Citizens' Energy Task Force and Save Our Unique Lands against MISO, the Midwest Reliability Organization, and a long list of utilities.  You can read FERC's Order here.  The complaint alleged that a transmission line included in MISO's MTEP plan in 2008 violated reliability standards and would make the bulk electricity system unstable.

The Commission did not launch an investigation into the reliability of the MISO transmission system, and no testimony by an expert alleging reliability violations was submitted with the complaint.  Instead, FERC treated the complaint as an unsubstantiated allegation, upon which it is not required to act. 

FERC's dismissal was also based on the premise that the citizens are RTO/ISO stakeholders, and should have been participating in MISO's transmission planning process that approved the subject transmission line all the way back in 2008.  FERC gives great deference to the decisions of its regional transmission organizations.  If FERC started second guessing RTO/ISO decisions, it would be a never-ending spiral into micro-managing approval and siting of transmission projects, something FERC has no authority to do.

FERC's authority extends to ensuring that the regional transmission planning process is open and transparent. MISO (and other RTOs/ISOs) are complying with the spirit of FERC's Order No. 890 by theoretically making their planning process open to citizen participation.  If the citizens choose not to participate, they cannot complain about the process later.  Let's make an analogy here:  It's not okay to violate a law and then claim you were unaware of the law, so therefore you are innocent of breaking the law.

However, citizen "stakeholder" participation in the regional transmission planning process only works on paper (or in theory).  It doesn't translate to real life.  Regional transmission organizations are not consumer friendly.

An RTO/ISO is an association of manufacturers or suppliers (of electricity) with the purpose of maintaining prices at a high level and restricting competition in order to promote their own self-interest.  Coincidentally, this is also the defined construct of a cartel.  Only members of the regional planning cartels are permitted to vote on inclusion of transmission projects in the regional plan.  Consumers can never legally be members entitled to vote.  Consumer participation is limited to attempts to convince the voting membership to see things differently and in what may not be the company's financial best interests (which is the functional equivalent of screaming into a pillow).  A consumer can never be a stakeholder with footing equal to that of an investor owned utility with a planned for-profit transmission project.

Here's why the "stakeholder" premise does not work for consumers:

1.    Most consumers are unaware that regional transmission organizations exist.  The RTO/ISO does nothing to foster understanding or recruit the interest and participation of consumers.

2.    The regional planning process is highly technical and incomprehensible to nearly every consumer.

3.    The regional planning process is time consuming and getting more so every day.  As recently reported in the former PJM Insider, PJM is hav­ing trou­ble pro­vid­ing enough facil­i­ta­tors to run meet­ings on the prob­lem state­ments (because there are too many of them).  Consumers don't have the kind of time necessary to participate as a fully-engaged stakeholder.

4.    State agencies tasked with protecting residential consumers are too underfunded and understaffed to effect meaningful stakeholder participation (see #3 above).

Therefore, consumers are not, and can never be, equal stakeholders, except on paper in FERC orders.

What's the solution? 

PJM states have formed The Consumer Advocates of PJM States (CAPS) group and have been recruiting for someone to serve as a PJM monitor/participant on their behalf.  While this is a step in the right direction, it still doesn't solve problems 1, 2 and 3 above.  The same majority of consumers who don't know regional transmission organizations exist also don't know that state consumer advocates exist (which makes their jobs thankless, sort of like wetting your pants in a dark suit -- it gives you a warm feeling, but no one notices).  We'll have to wait to see if this approach is effective.

There is no designated or funded consumer advocate on a federal level.  While consumers have state advocates to participate on their behalf, there is no federal counterpart to help with the regional or federal workload.  Congress has flirted with setting up a consumer advocate at FERC, but nothing has ever been accomplished.

Must the townsfolk storm the regional planning castle in huge numbers?  They'll probably come fully decked out with torches and pitchforks... and stakes, they'll be holding stakes that they intend to pound through the heart of the transmission building cartel beast that taxes, frustrates and confounds them.