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NextEra Files for Transmission Rate Incentives for its MARL Project

12/16/2023

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On November 22, NextEra filed an application at FERC to be granted certain transmission rate incentives for its MidAtlantic Resiliency Link, or MARL transmission project.  Of course, we know that the PJM Board of Managers didn't approve the MARL project until December 11.  But somehow NextEra was so certain it would receive the assignment that it felt free to apply for incentives for its proposed project ahead of time.  And let's just leave that fact on the table to contemplate.

Here's a link to MARL's filing.  It's huge, but you may want to only pay attention to the first 17 pages and the supporting testimony... for now.  The weird-looking multi-page tables appended at the end of the filing are MARL's formula rate.  This is how MARL determines how much to charge ratepayers for the project.  The ones attached to this filing are blank, but MARL will be making future filings with the numbers filled in.  That's a whole different process that perhaps we'll examine in the future.  The request for incentives is enough complicated crap for today's menu.

FERC's transmission incentives -- a long, complicated story.  Pull up a chair and get a cup of coffee, you're going to need it.

Back in 2005, Congress decided that not enough electric transmission was being built.  They reasoned this was what caused the 2003 Northeast blackout (I beg to differ, but that's a whole different blog for another day).  Congress passed Sec. 219 of the Energy Policy Act directing the Federal Energy Regulatory Commission to establish, by rule, incentive-based rate treatments to promote capital investment in electric transmission infrastructure.  Over the course of several proceedings, FERC developed a number of incentives to financially reward and protect utilities who undertook new transmission projects.  The incentives have been looked at several times since, with the most recent Notice of Proposed Rulemaking issued in 2020.  Although hundreds comments were filed by regulators, utilities, special interest groups, and consumers, FERC has not yet acted.  That docket, RM20-10, is still sitting around collecting dust.  No one seems to find this more frustrating than FERC Commissioner Mark Christie, who finds himself obligated to approve them every time, but issues virtually the same opinion every time that several of them are unjust and unreasonable and need to be reformed.  FERC is at an impasse.

FERC's incentives include ROE adders, hypothetical capital structure, pre-commercial cost recovery, accelerated depreciation and advanced technology, and two that MARL has requested, abandonment and CWIP in ratebase.  I've explained them ad nauseam in a special section of this blog, here.

MARL begins by telling FERC that it has already requested and been approved for several incentives, along with a formula rate, for an earlier transmission purchase.  Those incentives are:  
(i) recovery of all pre-commercial costs not capitalized and authorization to establish a regulatory asset that will include all such expenses that are incurred prior to the time costs first flow through to customers, including authorization to accrue carrying charges and amortize the regulatory asset over five years for cost recovery purposes (“Regulatory Asset Incentive”); (ii) use of a hypothetical capital structure of 60% equity and 40% debt until NEET MidAtlantic Indiana’s first project achieved commercial operations (“Hypothetical Capital Structure Incentive”); and (iii) use of a 50-basis point return on equity (“ROE”) adder for Regional Transmission Organization Participation (“RTO Participation Adder”). 
Now NextEra wants two additional incentives for MARL, along with the ability to use them for any subsequent projects.  
(i) recovery of 100 percent of prudently-incurred transmission-related costs of the Project if it is abandoned or canceled for reasons beyond the control of NEET MidAtlantic Indiana (“Abandoned Plant Incentive”); (ii) authorization to include 100 percent of prudently incurred Construction Work in Progress (“CWIP”) in rate base for the Project (“CWIP Incentive”); and (iii) authorization to assign the requested Abandoned Plant and CWIP Incentives, if approved, to any newly-formed PJM affiliate of NEET MidAtlantic Indiana that is involved in the development and construction of the MidAtlantic Resiliency Link Project.​

What are these two incentives, and what do they do?

First, let's look at the abandonment incentive.  It guarantees that the transmission owner (MARL) may collect all its prudently incurred costs for the project in the event that it is subsequently cancelled (abandoned) before being built.  First of all, the cancellation has to be out of the control of MARL, such as PJM cancelling the project due to an inability to get approvals or meet in-service dates.  PJM could also discover in a subsequent analysis that the project is no longer needed.  If that happens, MARL would need to make another filing with FERC detailing all the money it has spent on the project and a statement that they were all prudently incurred.  If FERC approves that filing, ratepayers would have to reimburse MARL for its costs, even though nothing is ever built.

Abandonment happens all the time.  One of the most famous is the PATH project that was abandoned in 2012 before a shovel ever hit the ground.  That debacle cost ratepayers around $500M, for a project that never happened.

In deciding whether to grant the abandonment incentive, FERC evaluates project risks.  If the project presents financial or other risks to the utility, then FERC grants it.  Therefore, MARL has told FERC that its project is extremely risky in order to be granted this incentive.  Some of the things MARL told FERC:
In addition, the Project requires construction of approximately 129-line miles of 500 kV transmission lines, 24 miles of which is located in a greenfield corridor that crosses through Loudoun County, Virginia, which is one of the wealthiest counties in America. Project opposition from residents in this County is foreseeable and may result in permitting delays, undergrounding requirements that may increase the costs associated with the Project, and/or litigation over the Project’s scope and construction. The Project also spans across four different states—West Virginia, Virginia, Maryland, and Pennsylvania—which will require NEET MidAtlantic Indiana to obtain necessary permits and approvals from a large number of different state and local regulatory bodies and will subject the Project to numerous different environmental and other regulatory standards and requirements. Finally, the Project is directly reliant on the construction of a 36-mile increment of 500 kV transmission lines being developed by First Energy as the incumbent transmission owner. Delays or cancellation associated with First Energy’s construction of its 36-mile increment may impact NEET MidAtlantic Indiana’s ability to obtain permits, finalize construction, and place into service the MidAtlantic Resiliency Link Project in a timely fashion. 


Additionally, the Commission has also recognized that large, new interstate projects can face substantial risks and challenges not presented by more ordinary transmission investments. Like other large interstate projects, the MidAtlantic Resiliency Link Project will span across four different states and many more localities, each with its own regulatory permitting requirements. The Project also traverses across regions of Virginia, such as Loudon County, that have traditionally been litigious when it comes to new, significant transmission build, and similar opposition is expected here. This opposition could result in Project delays or the inability to obtain certain required permits, such as a certificate of public convenience and necessity, ultimately resulting in cancellation of the Project for reasons outside of NEET MidAtlantic Indiana’s reasonable control.
Could those things happen?  Of course, but consider that MARL is making more of them for FERC's benefit.  Perhaps it's more useful as a list of vulnerable spots for opponents to attack.

The second incentive MARL requested is CWIP in ratebase.  CWIP stands for "Construction Work in Progress."  CWIP (pronounced "quip") is the financial account where all the project's capital costs are recorded until it is completed and enters service.  It can be treated two different ways.   

The first is for the company to add interest to the account each year as it slowly builds during construction, and to begin collecting the costs (plus interest) once the project goes into service.  Utilities find this difficult because they have to handle their debt until the project is finished.  It hurts their financial health to have huge amounts of unreimbursed debt on their books.  It can also hurt ratepayers because when collection begins, it can create huge, lumpy rate increases.

The second is for the company to include CWIP balances in their ratebase and earn a return (interest) on them right away, while the project is being constructed.  With this incentive, MARL will begin earning a profit on the money it spends as it spends it.  This allows MARL to pump this profit back into the project, instead of investing more of its own money or borrowing.  It helps their finances.  It can also help ratepayers because they begin paying for the project during construction, little by little, as the costs of the project add up.  Instead of a huge rate increase all at once, ratepayers pay increasing costs over time.

What's a ratebase?  Now we're going down the rabbit hole of transmission rates.  It's extremely complicated, but I'll try to give you the Cliff's Notes version.  FERC uses formula rates for transmission.  A formula rate is a formula that determines the utility's rate each year so that rates can change without a full rate process each year.  Instead of a dollar amount, the utility's rate is the formula itself.  The formula is that set of schedules, tables, and attachments that is stuck onto the end of MARL's filing.  That's MARL's formula rate.  Each year, the formula is populated with amounts from MARL's financial records and calculated using the formula to come up with an actual dollar figure.  Ratebase is the sum of all the accounts that earn a return (interest).  Ratebase, plus return, is added to the utility's Operations and Maintenance, Administrative and General costs, plus taxes, to come up with the yearly revenue requirement.  We pay the revenue requirement each year.   It is filtered through PJM's billing system and then the billing systems of the local utilities who send us our bills.  The utility must hold public rate meetings each year to present the result of their formula rate calculations.  Interested parties, described as those that pay the rates, can ask questions and submit discovery requests to see how the rate was calculated.  Yes, that includes people like us who pay an electric bill that includes some portion of these costs.  But that's all information for later...

A very simple explanation for how ratepayers pay for transmission is to liken it to the home mortgage that we're all familiar with.  The utility pays to construct the project (like the bank pays for your home) and then we pay the utility back over time, plus interest, just like we pay our home mortgage.

Because MARL made this filing so early, before its project was even approved by PJM, the window to intervene and file comments on its request for incentives has already closed.  We cannot act on it.  However, I can pretty much tell you how it's going to end... FERC will approve it and Commissioner Christie will file a statement saying that those incentives need to be re-examined and possibly cancelled.  Therefore, I can't feel too bad about not having to write another FERC filing that does no good.  Comm. Christie has got our backs.

And, in closing, I'm going to make one more observation.  As we all saw during PJM's planning process, these utilities are falling all over themselves to be selected to build new projects.  It is a COMPETITIVE process, and that only happens when participants WANT to be selected.  FERC's incentives are meant to encourage utilities to build transmission even though they may not want to, or if it is financially risky for them to do so.  Are incentives really necessary in a competitive planning process?  Without them, would these utilities still be competing to be selected?  Transmission is still incredibly profitable, even without incentives.  Transmission owners earn hefty returns on the money they invest building them.  Transmission returns on equity are set much higher than other market returns, so that building transmission is the most profitable place the utility can invest its money.  They have been as high as 16% when interest rates are up, and as low as 9% when the markets are down.  Even then, they are still much higher than anything you can find to invest your own money.  FERC returns are loosely tied to markets, so they fluctuate, but once FERC sets the ROE for a transmission project, it is set in stone until another proceeding is opened to re-examine it.  Begin a project when the market is up, and you get a high return that can persist for years, even when the markets change.  Transmission is a long-lived asset, and it is paid for by ratepayers over its useful life.  The expected life of many transmission projects is 40 years.  It's like a 40-year mortgage that we're going to have to pay.
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PJM Given Regulatory Authority by Federal Court

12/15/2023

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I'm sure even PJM's jaw dropped when it read a recent court decision that essentially says that a state MUST approve a transmission project planned by PJM.  PJM has been given new power by a judge legislating from the bench.  Surprise!

In Transource Pa. LLC v. Defrank, CIVIL 1:21-CV-01101 (M.D. Pa. Dec. 6, 2023), the court determined that the Pennsylvania Public Utility Commission's denial of Transource's application to build the Independence Energy Connection market efficiency project was unconstitutional.

When I first read Transource's screwy arguments appealing the PUC's decision, I laughed.  Maybe that was because I know too much about federal laws governing transmission, how the different actors relate to each other, and how PJM's planning process works to even entertain such a ridiculous argument.

Here's a clip from the overly long opinion that sums up what's at stake here:
“Defendants also argue that the PUC's decision related to siting, and not regional planning, because it was procedurally different from PJM's transmission planning process. (Id. at 12-14.) In support of this argument, they point to various ways in which PJM's process was purportedly faulty, whether by not conducting evidentiary hearings, taking sworn testimony, permitting cross-examination, or purportedly basing the benefit-to-cost analysis on stale information. (Id.) Meanwhile, the PUC's determination was based on timely information which provides, in Defendants' words, “an important procedural check on the unlitigated, un-reviewed conclusions reached by PJM.” (Id. at 13.)

If they were not allowed this important procedural check, Defendants argue, state laws would merely be a “rubber-stamp [of] every RTO-approved transmission line application.” (Id. at 14 (internal quotation marks omitted).) Defendants argue that the court need not parse the meaning of FERC's instructions in Order 1000 “because FERC has clearly instructed that its jurisdiction did not reach siting and permitting.” (Id.) Here, the PUC's decision was made “after the transmission planning process was completed. The PUC decision, therefore, was a valid exercise of its siting authority.””)
But yet the Court ruled that the state PUC must accept PJM's determination of "need" for this project and substitute it for any investigation of their own.  Pennsylvania's statute that the PUC operates under requires the PUC to make the following determination:
To obtain approval for their application, public utilities must satisfy the following requirements by a preponderance of the evidence:

1) That there is a need for it.
2) That it will not create an unreasonable risk of danger to the health and safety of the public.
3) That it is in compliance with applicable statutes and regulations providing for the protection of the natural resources of this Commonwealth.
4) That it will have minimum adverse environmental impact, considering the electric power needs of the public, the state of available technology and the available alternatives.
Public utilities must satisfy these criteria in the opinion of the PUC, not PJM.  Just because PJM finds a project "needed" does not obligate the PUC to make the same finding.  Transmission permitting is state jurisdictional.  The only space for FERC-regulated PJM or federal transmission permitting is under Sec. 216 of the Federal Power Act, where the U.S. Department of Energy may designate a National Interest Electric Transmission Corridor in order to give FERC backstop permitting authority.  The Transource project does NOT have a corridor, therefore permitting is entirely up to the state.  In a state proceeding without a corridor designation, PJM's opinion about the project is just that -- another opinion for the PUC to consider in its evidentiary findings.  The PUC did not find PJM credible.  It was not required by state or federal law to do so.

In fact, if this absurd decision holds, then it will never be necessary for another regionally planned transmission project to ever apply for a NIETC.  It won't need one because PJM's determination of need trumps a state determination and the only thing left for the state to do is to decide where to put it.  This court has interpreted "siting" in isolation from "permitting."  It's siting AND permitting, and under Pennsylvania law, the PUC must make a determination of need before it permits.  There is absolutely NOTHING in federal law that supersedes Pennsylvania law in this area.  Federal law cannot require the PUC to defer to PJM's findings of need.

So, the PUC has 30 days to appeal this travesty.  If it does not, this precedent will be used to cut off every state utility commission from doing anything other than rubber stamping projects PJM or another FERC-approved RTO/ISO selects.  PJM is a GRID PLANNER.  It has no authority to site and permit transmission.  There is absolutely no reason for this court to give them new authority that does not exist in the law.

​This cannot stand!
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PJM's Board Approved New Transmission Projects - Now What?

12/12/2023

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Yesterday, PJM's Board of Managers quietly approved over $5B of new transmission designed to import electricity created by coal, gas, and nuclear to Virginia's data center alley and the Baltimore area, where thousands of megawatts of coal-fired power plants are set to close next year.  New industrial load and closure of dirty generators is being solved by importing dirty generation from other states to the DC-metro area, an area that likes to pretend it's embracing clean energy and lowering its carbon emissions.  Hardly.  Clean energy policy is all smoke and mirrors... literally.

First, let's look at PJM's announcement.
The proposed solution includes new substations, new transmission lines and improvements to existing facilities. A majority of the project components use existing facilities and rights of way (through either repurposing/rebuilding existing assets or paralleling existing rights of way, which can reduce costs and minimize impacts to local areas). There are sections that would be new construction on land without existing transmission lines, known as greenfield development.
Well, that's a complete and total lie.  Apparently I have found the weak spot.  Paralleling existing transmission lines with new transmission lines on greenfield ROWs does NOTHING to reduce costs.  How so, PJM?  A new greenfield project would cost the same no matter where it is sited.  In addition, wreck and rebuild projects that expand existing ROW have additional costs of tearing down the existing line before a new one can be built.  As far as "minimizing impacts" that is also a huge lie.  Transmission lines are not like Lay's Potato Chips where you can't just have one.  Continuing to expand existing transmission corridors is the antithesis of environmental justice.  Nobody who lives with one (or more) transmission line across their property wants another one.  Impacts can actually be GREATER when paralleling existing ROWs because ROW expansion further intrudes into the host's land and gobbles up things built outside the current ROW, such as fences, barns, playsets, swimming pools, and water wells and septic fields.  Loss of water and sewer makes a property uninhabitable.  Expansion of existing corridors is like living next to an active volcano... they slowly expand until they overtake you altogether.  Just remember, if a utility builds transmission through your property, you are subject to another, and another, and another.  Not fair for you, not fair for anyone else.
PJM does not site the facilities or transmission lines nor determine their routes. This is the next step in the process and will be completed by the developers designated by PJM to construct the projects.
That's right.  I've been saying this over and over, but here's one more for the road.  The next thing the transmission company assigned the project will do is a detailed routing study that attempts to avoid homes and other structures, parks, historic resources, public land and environmental constraints.  What comes out of that process is a collection of competing short route segments that can be pieced together to form the actual proposed route.  The transmission company expects you all to fight with each other over these route segments in order to push it out of your own backyard and into your neighbor's.  The company asks you to comment on individual segments with the hope of finding the ones with the least objections.  Tough luck for you if you live on one of them.  Once the proposed route is established, the transmission company will file an application with the jurisdictional state utility commission.  The company asks that the commission approve the route and issue a permit to build the project.  This is a long, court-like process in which impacted parties can participate, either with or without a lawyer.  It is recommended that you do participate, if nothing else simply to preserve your right to appeal a decision you don't agree with.
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And take a look at those cost allocation tables in the attachments to PJM's announcement (Page 55). The lion's share (44%)  of the more than $5B cost will be paid for by Dominion's customers.  However, more than 10% will be paid for by customers in PJM's APS region, which includes not only portions of northwestern Virginia, but also more than half of West Virginia and big chunks of Pennsylvania.  Why are struggling communities in rural areas paying for a giant chunk of transmission that benefits some of the richest corporations in the world, such as Amazon, Google and Facebook?  West Virginia and Pennsylvania are not getting any benefit whatsoever, except what little bit of "reliability" leaks out from keeping the data centers and plant closures from crashing the grid altogether.  Why do others have to pay to shore up something that someone else broke?  This is not like historic load growth that came in small and widely dispersed increments and therefore affected the region at large.  This is like plunking a large city down all at once and plugging it in.  We can (and PJM has) point right to the cause of the new transmission.  Least they can do is pick up their own costs.  It is no longer just and reasonable to expect everyone to pay for the damage done by the few.  And if you think that's bad, check out the regional load ratio share allocations -- a portion of the costs that is allocated across the entire PJM region.
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These are all the other utilities who have to pay a portion of the costs for new transmission to serve data centers.  You can locate these utility acronyms on this map.
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Check out the ComEd region, for instance.  This utility in northern Illinois will pay for 13.39% of the shared costs, a larger load-ratio share than Dominion (13.32%).  Imagine how they feel about paying for transmission that supports new data centers in Northern Virginia and closing coal plants in Baltimore.

If you're totally confused by PJM's cost allocation system, just wait... there's bound to be some fireworks when PJM asks for FERC approval to allocate the cost this way.  More about that when it happens.  For now it's enough to know that PJM's historic cost allocation system does NOT work for these projects and therefore must be changed in order to remain just and reasonable.

PJM's White Paper (that they managed to hide until AFTER the Board meeting) pretends that your participation mattered.  Look what it said:
Project needs and recommended solutions as discussed in this report were reviewed with stakeholders during 2023, most recently at the October 31, 2023, and December 5, 2023, TEAC meetings. Written comments were requested to be submitted to PJM to communicate any concerns with project recommendations. All correspondence addressed to the PJM Board are available at the Board communications page.
All your letters to the Board got filtered through the TEAC and summarized.  The Board didn't read any of them.  I'm thinking that muzzling of stakeholders is NOT in PJM's beloved Manual of procedures.  Therefore, it most likely violates the rules it is supposed to follow that have been approved by FERC.  Anyone can file a complaint about that.

So, despite our best efforts, the PJM Board has approved the Window 3 projects.  Now what?

The real battle is just beginning.  Buckle up... it's likely to last for years.  Delay is our friend.  The enemy of our enemy is also our friend.  All of this will become crystal clear in due time.

But what should you do right now?  Reach out to your neighbor, ask them to reach out to their neighbor.  Form neighborhood groups that coalesce into town groups that coalesce into county groups that coalesce into state groups that coalesce into multi-state groups.  We're all family now.  Gather your people.  

And then circle the wagons.  Transmission opposition is as much a strategy battle as any other.  Keep your strategy discussions private.  The transmission companies will be desperate to know what you're planning so they can try to beat you to the punch.  They will infiltrate your groups and stalk you online in the creepiest way possible.  But don't be so paranoid that you aren't accessible to new folks.  There are layers to transmission opposition information dissemination.  After you meet a few of the utility wonks at transmission company public meetings you may be able to recognize them for what they are when they manage to infiltrate meetings.  I think after 15 years, I can practically SMELL them when they sneak into the room.  Once, I was guest speaking at a public meeting for a group when I noticed a guy way in the back row that positively screamed "utility guy" to me.  It wasn't so much his look as it was his behavior.  After I was done speaking, I pointed him out to the host leader and she told me he did work for a utility, but that he was secretly on their side.  Lesson:  not all utility nerds are bad guys, but there are plenty that are going to frustrate you and try your patience.  Take a deep breath.  Find the humor in the situation.  It helps.

When you've got your group together, feel free to ask me, "What's next?"  However, let's keep that out of public social media groups and out of public blogs.  I'm always available to answer questions or provide advice.

WE CAN DO THIS!

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PJM Meeting Aftermath

12/7/2023

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Here's another letter to PJM's Board of Managers, one that comes AFTER Tuesday's 8 hour Transmission Expansion Advisory Committee meeting.

If you attended that meeting hoping your participation could affect change, you can share this attendee's pain and disillusionment.

PJM deserves every.last.word of this letter...
​Dear Board Members,

I was a phone call member for yesterday's meeting. Yep, the entire meeting. I listened to the initial acknowledgement of the hundreds of letters you received. The slight defensive tone was hard to dismiss. I heard what was said about "once the Board approves the plan" more opportunity will arise for the public to voice there concerns. I also did note, you welcomed phone calls in and then moved onto your presentation. 

I listened to the need to retire some equipment nearing the end of it's life and the need for the massive output in the near future. I heard quotes of millions of dollars being passed around like Monopoly money, if I'm honest. We all know the true source of those finances. I also heard how and why we need the additional extensions and how soon those should be in place.

What I felt was completely ignored was the elephant in the room; the people being effected by this massive build. I followed Keryn Newman's line of questioning perfectly; what happens to the folks who loose their drain fields or the viability of their wells with the expansion process? The gentleman couldn't answer. He didn't have one. Crickets. What happens to the woman off Short Hill Mountain that already puts up with these towers and now is possibly slated for an extension to run south off her property as well. Where are the studies to show the placement of these towers are safe for Indigenous wildlife, showing it's safe for children playing near by, and even equally important, how the people living in these paths are supposed to maintain their quality of life.

It was evident that more studies for an accurate path were formulating and town halls were going to be promoted, BUT, the cow will be out of the barn at that point. Once a project is passed rarely are we able to go back and discount it. I felt the meeting was merely checking boxes; you allowed public transparency, as well as opportunities to ask questions, placated opposition and now you were simply going to proceed how you initially wanted. Us be damned. 

PJM, please find another way to get your power where it needs to go. I think the township of Waterford has the most serious claim, HOWEVER, that does not make the rest of us of less value. I implore you to do the right thing. 
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Take a Ride on PJM's Gaslight Express

12/6/2023

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Yesterday, I took another ride on PJM's Gaslight Express, also known as the Transmission Expansion Advisory Committee meeting.  There's just something exhausting about an 8 hour meeting where automatons read out loud from documents you've already read to yourself.  When followed by Q&A that one participant likened to "nailing jello to the wall," you can lose all will to live. Thank goodness that farce is over for the time being!
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Yesterday's meeting began with a speech by someone named Susan.  Susan did not have a last name or a job title (although we are required to say our names and affiliations each time we speak during a meeting).  Susan must be quite famous, like Cher, or Prince, although I've never heard of her in the 15 years I've been doing transmission.  Susan said that poor PJM has a problem because too much coal/gas generation is closing down in Eastern PJM and solar is not replacing it "one for one."  In other words, shutting down an 800 MW coal-fired plant in Baltimore is NOT being replaced with solar (or wind or storage or any other renewable).  Therefore, the only thing PJM can do is build transmission.

When I "asked a question" and reframed what Susan said to apply to the entire PJM region, a different PJM guy jumped in to say that was wrong.  Why was it only wrong when I said it and not the famous Susan?  Is it me?  Is it you?  Or are we all going to sit here in the dark in 10 years and say, "We should have listened to Susan!"  I stated that PJM is building transmission to existing coal and gas plants in WV and PA in order to replace the generation that is shutting down in Baltimore.  This is a game of hot potato, because the generation in WV and PA will soon follow the generation in Baltimore as we head further down the "clean energy" path.  At some point, there will be NO generation left.  What happens then?
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PJM changed its tune and, according to Loudoun Now,

Seiler said they were not replacing coal fire generation with coal fire generation from somewhere else.“It’s actually coming from the entire region that includes a mixture of fuel types including wind, solar, batteries, combined cycle gas units, and nuclear power plants as well,” he said.

Except there is not enough wind, solar and batteries in any of the places the new lines go to replace the coal fired generation, just like there wasn't enough of it to replace the generation that closed in Baltimore.  Here's PJM's current fuel mix:
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As usual, PJM's load is sucking up the juice produced by coal, gas and nuclear, just the kind of resources that WV and PA are producing in excess.  Baltimore is only producing solar anymore.  So, don't tell me that Baltimore is replacing its coal with solar and wind from WV and PA.  It's just not believable and it doesn't even make sense.  It's nothing but gaslighting.

I asked the age of the 500 kV transmission line in my neighborhood that FirstEnergy is going to do some work on soon.  FirstEnergy will be replacing some old station equipment that doesn't function correctly anymore.  I wondered if the entire line, including the lines (conductor), maybe could use some updating to increase its capacity.  FirstEnergy has no idea of the age of one of its largest transmission assets.  Shut down that discussion, and turn up the gas.

I asked a series of questions about several of the PJM projects in this plan.  They were simple questions that deserved simple answers.  Instead, I got at least 10 minutes of double speak and still don't know the answers I was seeking.

First, I wanted to know how many high-voltage transmission lines currently exist in the Doubs-Goose Creek transmission line corridor in Frederick and Montgomery Counties, Maryland, and how many would be added by PJM's plan.  Existing now:  1- 500kV line and 2- 230kV lines.  After PJM's new plan:  2-500kV lines and 1- 230kV line.  Maybe.  I'm really not sure because the gas was turned up so high it was hard to find an answer in the toxic cloud.  I asked this question because PJM has insinuated that the greenfield 500kV line (Project 853) through Western Loudoun may have to be re-routed east onto Doubs-Goose Creek.  If that happens, the corridor would have 3- 500kV lines and one or 2- 230kV lines.  That's like over 2000kV of electricity in one corridor that may be 250 ft. wide at the most.  This corridor runs through private property, next to homes, schools, and other parts of the built community in Frederick and Montgomery Counties, MD.  The people who live there aren't going to like it anymore than the folks in Western Loudoun like a single 500kV line.  I asked why PJM thought moving the line from VA to MD because of opposition would somehow create a different result?  And that's when PJM really turned up the gas and I lost consciousness.

I asked what PJM was ALREADY building between Aspen and Golden due to the fact that it was not only in PJM's most recent package of projects, but also being actively opposed by residents of Lansdowne.  PJM started talking about Mars and Wishing Star and a different immediate need project already in the works, but said that project had nothing to do with Aspen to Golden.  That's good news for the NoTowerson7 folks I suppose... they are opposing a transmission project that doesn't exist!  I hope somebody lets Dominion know so they stop trying to build it.  Or maybe they also need some of PJM's gas?

And finally, I asked about the new 500kV transmission line across Jefferson County, WV.  As proposed by NextEra, it would expand the easement by 30 feet.  But since PJM has now awarded that project to FirstEnergy, is FirstEnergy held to that same amount of expansion, or can they expand the easement 50 feet, 100 feet, 500 feet?  I got a lot of nonsense in response that basically indicated that FirstEnergy can build whatever it wants, but PJM also said that FirstEnergy has promised them that it can do the rebuild WITHOUT EXPANDING THE EASEMENT AT ALL.  I guess FirstEnergy has their own supply of special gas because PJM acted like they believe that, even though I remember that we found out during PATH that the existing 138kV easement is only 75 feet.  I don't see a double-circuit 500/138kV on lattice towers fitting in there without easement expansion.  When FirstEnergy bid to install a new 500kV line on that corridor, they asked for a new 165 ft. easement.  But PJM chooses to believe whatever it wants to believe for now.

I also asked PJM when we would see the cost allocation table for these new projects.  PJM indicated that would either be part of the white paper for the Board, or issued shortly after the Board approves the projects.  Then, of course, I asked where we would find the white paper.  I think it may appear in the TEAC documents, but like all "answers" PJM issued yesterday, it was about as clear as mud.  The white paper will be written by the TEAC for the education of the Board of Managers before they make their decision on December 11.  In it, the TEAC makes its recommendation and summarizes the issues for the Board.  Do you think the Board is going to read all the other reports, and all the letters you have written, or just rely on the TEAC's summary to make its decision?  Pretend you're a busy Board member when you imagine this scenario.  The TEAC guys even gaslight their own Board of Managers to manipulate the decision they want.

That said, I hope everyone paid close attention to the nonsense Sami was spewing when "answering" my question about pushing the greenfield portion of 853 over onto the Doubs corridor.  I heard that such a re-routing is almost a given at this point... but maybe it was the gas.

I thought I was done asking questions, but I couldn't resist poking the guy giving detail about the 853 project in Jefferson County.  I explained the problem with expanding existing rights-of-way into the backyards of people who live along the existing line.  Expanding into their backyard is going to take their well, septic system, and anything else they have built in their own backyard because those things are not compatible with transmission easements.  But that was jumped on by the gaslighters, who pretended they did not understand the problem with calling new greenfield easements parallel to existing ones "brownfield."  I've brought this up endlessly!  The "answer" is that we cannot assume those things are going to happen, therefore they are not an issue.  Let's pretend they won't happen!  But they WILL happen.  I know at least one person for whom that is REAL right now.  But if PJM ignores it now, it would only surface later, when there's no chance to correct it.  That's what PJM prefers.  So there is going to be a long string of homes in Jefferson County without water or sewer, or both.  Essentially, these homes will no longer be suitable to live in.  What's the compensation for that and why would ratepayers have to pay for that routing error that could have been corrected from the beginning?

I could hear someone over the phone trying to ask a question who was being ignored.  Found out who it was and put her name in the webex queue.  She asked where the turning point for 853 from brownfield to greenfield was because she suspected it was in her front yard, based on the maps and narrative.  They turned up the gas for her, too, and pretended those details haven't been worked out.  If that's not worked out, how can any of these cost estimates be anywhere near accurate?  Good question!  FirstEnergy is building the brownfield part, and NextEra is building the greenfield part.  Where one stops and the other begins is a crucial fact for cost estimates.  She never did get an answer to her question.  She's just supposed to live in limbo until the utilities and PJM work this out sometime AFTER project approval by the Board of Managers.

Like trying to nail jello to the wall.  That's a perfect description for PJM's "stakeholder engagement."  They spew a bunch of nonsense but none of it is relevant or sensible.  And that summarizes the whole of yesterday's meeting.

PJM is not going to change its mind about these projects before sending them to the Board of Managers for approval.  I didn't expect any different.  My only reason for bothering with this meeting is to try to get some clarity on certain issues.  PJM couldn't even provide that.

Next up... the Board of Managers will make their decision on December 11.  The TEAC wants you to think that's all a done deal and that the Board will simply rubber stamp whatever TEAC asks for... because the lights will go out unless they do.  Is it really that simple?  Does the independent Board ever think for themselves?  Do they ever question the gaslit nonsense they are fed by the TEAC?  At least we'll get that question answered next week.
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Another Letter to PJM Board of Managers

12/6/2023

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I am writing to express my strong opposition to PJM’s 2022 Window 3 RTEP “solution” that will put an enormous burden on PJM ratepayers in the Mid-Atlantic area. The expected $5.4 Billion dollar cost to be shouldered by ratepayers to support an industry that includes some of richest companies in the world is an abuse of PJM’s power.
At the September 5, 2023 TEAC meeting, I asked if PJM had engaged in conversations with Virginia state officials about their plans to advance dependable, dispatchable generation in Data Center Alley as an alternative to a transmission solution only approach. The negative, volatile reaction of your employees running the TEAC meeting was essentially to squash any and all ideas that PJM would ever have that type of conversation with state officials. Certainly, the Data Center Alley companies build of back-up generation on site in the form of diesel generators is apparently fine with Virginia officials. So again, please explain why PJM will not have that conversation? Your own Market Monitor has told PJM over and over again that a process to compare the building of generation vs. building transmission should already be in place.
The only two states in PJM’s Mid-Atlantic region that have excess generation capacity to send to Data Center Alley are Pennsylvania and West Virginia. What happens to PJM’s “solution” when the Biden Administration fulfills their promise to shut down all the coal-fired plants in the country? What happens when PA and WV are tapped out with their excess generation capacity? How close are we to that tipping point? Will this 2022 Window 3 solutions be for naught when there is no power to send?
Is PJM sure this time, that the transmission that you are ordering will be the last time that the same communities are asked to shoulder this burden? Wasn’t it just in 2017 and again in 2021, that the MD/PA border region in Harford County, MD and York County, PA experienced backbone transmission projects? What financial benefit does our area receive in tax revenues from Data Center Alley? NONE! If the State of Virginia wants to keep receiving the tax revenues from data center development, then they need to man up and build the necessary generation to support this type of development. The same communities should not be asked once again to shoulder this burden.
The reality is, that green energy cannot provide sufficient electricity to meet the needs of our Country at this time. States with ambitious green agendas are being disingenuous to their citizens. Shutting down reliable, dispatchable generation on the hope that wind, solar and battery storage can be effective in supplying electricity is a fool’s errand that will only increase electricity costs for ratepayers. ​

PJM knows that and should make it clear to the States that doing so will result in widespread loss of electricity for its 65 million ratepayers. Certainly, the 11-30-2023 OPSI letter you received clearly outlines the grave concerns associated with the 2022 Window 3 solutions and the need for reliable and affordable electricity for PJM ratepayers.
The PJM BOM should reject the 2022 Window 3 solution and look to find ways with the State of Virginia to build generation within the data center development areas. In addition, PJM should also find ways to protect the operation of our reliable, dispatchable generators until other technology has the capability to take its place.
Sincerely,
Patti Hankins Maryland Ratepayer 

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Letter to PJM Board of Managers

12/6/2023

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The PJM TEAC’s project recommendation to solve 2022 Window 3 issues does a disservice to all of PJM’s 65 million ratepayers and you should not approve it.

PJM’s plan is unlikely to be completed and will result in higher electric rates
PJM does not have a backup plan for the possibility that one or more segments of its plan cannot be built. Upon questioning, PJM staff said it would leave that problem on the doorstep of the designated entities. When certain segments are not approved, it makes other segments unnecessary. PJM staff is behaving like a Pollyanna, refusing to acknowledge the certainty that its plan cannot be fully constructed as proposed. This could lead to abandoned projects and increased rates for consumers, who will be forced to pay for project segments that never connect and are never built.
PJM staff has not shared any backup plan to maintain reliability and/or serve new load in the event that the recommended projects are not built by the targeted in-service dates. As more baseload generation retires prematurely but is not replaced with equivalent new generation, PJM is pushed closer and closer to grid failure. PJM would not be realistic, or even erring on the side of caution, to ensure continued reliability by relying solely on a massive new transmission build out that has an unlikely chance of success.
In addition, PJM staff’s assignment of hard to site greenfield projects to non-incumbents will only delay and complicate approvals. It is likely these projects cannot be built at all, and certainly not by entities unfamiliar with the impacted communities and state regulators involved. Like any transmission project on new easements, greenfield projects have a very low chance of approval and an almost certain chance of creating entrenched community and political opposition that leads to delay and abandonment.
The recommended plan is indisputably PJM’s biggest transmission endeavor to date. PJM’s recent track record of getting big projects approved and built is shockingly poor. Beginning with the PATH and MAPP project cancellations in 2012, several other large PJM projects have since been rejected and abandoned. There was the Monmouth County Reliability Project, rejected by the NJ BPU in 2018. There was the Transource Independence Energy Connection, rejected by the PA PUC in 2021. Community and political opposition drove all of these cancellations.
The shedding of over 11,000 MW of baseload generation combined with more than 7,500 MW of new data center load is a serious threat to not only the reliability of the grid, but to the pocketbooks of the 65 million consumers who depend on it. It’s the biggest threat PJM has ever faced. Such an enormous problem deserves a new approach. The new data centers in Northern Virginia provide benefit to some of the richest companies in the world, such as Amazon, Google and Facebook. The closing of baseload generators stems from the energy policies of certain states. But yet the entire region is being asked to fund a solution to this grid emergency created by the powerful few. It is unjust and unreasonable to place the costs and the impacts on portions of the region that will not benefit. If current planning and cost allocation rules require this travesty, then it’s time to change them because they have become unjust and unreasonable.
The Law of the Instrument is a cognitive bias that is often expressed with the phrase, "If the only tool you have is a hammer, every problem looks like a nail.” PJM’s transmission planning epitomizes the Law of the Instrument because it prioritizes transmission as the only possible solution. The PJM Market Monitor has been recommending for the past 10 years that PJM create “...a mechanism to permit a direct comparison, or competition, between transmission and generation alternatives, including which alternative is less costly and who bears the risks associated with each alternative.” (2023 Quarterly State of the Market Report for PJM: January through September, Pg. 719). PJM does not allow the market to work to drive the building of new generation in areas experiencing increased load or generation retirements. If PJM had adopted the Market Monitor’s recommendation in 2013, PJM wouldn’t be planning more than $5B worth of transmission as the only solution to solve generation retirements and data center load. PJM must now develop the recommended mechanism in order to allow for beneficial competition between transmission and generation to solve 2022 Window 3. The Board of Managers should reject the TEAC recommendation and order a new evaluation that compares new generation near load with new transmission to other states in the region in order to find the least cost, least impactful, solution for PJM’s ratepayers.

PJM’s Plan is Destructive to Clean Energy and Environmental Justice Progress
While governments and consumers are asking for cleaner power generation, PJM’s plan doubles down on fossil fuels by importing excess electricity from West Virginia and Pennsylvania. West Virginia and Pennsylvania still produce the majority of their electricity from coal and natural gas. Instead of cleaning up the environment in PJM states, increased dependence on fossil fuels actually increases pollution and regional haze. It makes no sense to close coal-fired plants in Maryland like Brandon Shores and Wagner, only to replace their supply with electricity from coal-fired plants in West Virginia. It’s just as dirty, except it’s in someone else’s back yard and requires $5B of new transmission that consumers will have to pay for.
By building new transmission to old coal plants, PJM ignores the questionable longevity of these existing generators under the EPA’s Clean Power Plan, or other state or federal clean energy legislation. The generators may retire before the new transmission line to the west is completed; creating a stranded asset that is not useful to the ratepayers who continue to pay for it. Certainly the expected life of the coal-fired generators is much shorter than the 40-year life of new transmission. New transmission to old power stations on the verge of retirement makes no sense.
PJM’s plan takes a huge step backwards for environmental justice and equity. While wealthy counties in the Washington, D.C. suburbs would increase their economic development, jobs and prosperity with new energy hog data centers, struggling communities in West Virginia face increased pollution from mining and burning coal to produce additional electricity to serve those data centers. West Virginians would also sacrifice their homes and working land to make way for new transmission lines to serve the data centers. As the final insult, West Virginia’s consumers would have to pay for PJM’s new transmission plan that hurts their own communities while benefitting politically connected communities elsewhere.
There has to be a better solution. This plan should be sent back to the TEAC with recommendations to develop a different plan that relies on new generation sources closer to load and produces less burden on communities that will not benefit, and therefore stands a much better chance of being approved and built in time to maintain reliability and serve new customers.
Any new transmission that cannot be constructed fully in existing rights-of-way must be buried within existing road, rail or other public rights-of-way. PJM must consider the use of buried HVDC along existing transportation corridors to transmit electricity from substations in the west, such as 502 Junction, to new substations in Loudoun County’s Data Center Alley. HVDC transmits more power with less line loss in situations where electricity is transmitted long distances without serving load along the way. Buried HVDC on existing rights-of-way reduces project risk from community opposition, delay, or cancellation. While buried HVDC may be more expensive up front, it produces considerable savings. Buried HVDC on existing easements does not require new land acquisition. It avoids public relations and state regulatory battles fueled by community opposition. Time is money and a project that can be built on time and on budget because there is no opposition creates an enormous savings. After buried HVDC is constructed on existing road and rail easements, it does not require perpetual vegetation management, and it is not subject to weather-related damage or sabotage. Outages are less frequent than with overhead transmission and the cost of just one outage caused by overhead line vulnerabilities can easily exceed the increased costs of constructing buried HVDC. Many transmission developers have found that the savings produced by buried HVDC obviates its higher up front cost.

PJM’s TEAC Process
PJM’s Transmission Expansion Advisory Committee has engaged in what I believe to be a deliberate campaign to misrepresent new transmission routes, while simultaneously attempting to thwart participation by non-member stakeholders. PJM’s maps of proposed projects continually misrepresented new greenfield transmission line proposals as brownfield. Maps were also inaccurate and did not match the written route narratives submitted by the proposing entities. PJM went through so many revisions to its maps that I have lost count. Is PJM’s mapping staff really that incompetent, or was the map debacle just a ruse to draw attention to the maps, instead of substantive comment?  I tried to discuss the issue of new easements adjacent to existing transmission lines at length with PJM staff because they insisted these new developments are “brownfield” developments. Brownfield developments are those that are entirely contained on existing easements. Anything that requires new easements, in whole or in part, is greenfield development. Adding additional transmission to existing corridors can actually be more destructive than greenfield routes in areas without existing transmission. The reason for this is that new communities have been built up along the edges of transmission easements that have existed for a number of years, even decades. The existing easements are hemmed in on both sides by new homes, schools, fire stations, churches, businesses, parks, and other developments. Creating a new transmission corridor on a new easement directly adjacent to the existing corridor will require the destruction of the existing community. This is not brownfield development. In contrast, a new line on a greenfield easement can be carefully sited to avoid homes, schools, fire stations, churches, parks and businesses. Brownfield can be, and often is, more destructive to host communities than greenfield.
After my provision of a written example of destructive brownfield siting (along with aerial photo), PJM staff said that they would be creating a new category for the maps to differentiate greenfield next to existing lines from brownfield. This appeared in one set of maps, but has since been eliminated, with PJM reverting back to painting all its new corridors as “brownfield or next to existing ROW.” Who is PJM trying to fool with this misrepresentation? Is it the communities who will host new lines? Or is it the Board of Managers, who may approve new transmission projects without full knowledge of the destruction they may cause to impacted communities because they have been incorrectly informed that the majority of the projects are brownfield? PJM staff is making an incorrect presumption that expanding existing corridors with new easements is preferable to greenfield lines, a view that is not shared by host communities. Since all opposition stems from community impact, PJM’s incorrect presumption does not serve to lessen opposition. It only serves to misinform the Board of Managers.
At the August TEAC meeting, I asked how impacted communities could share vital information about new or expanded easements that could be incorporated into the constructability reports to inform determination of risk. I was told that the public could comment verbally during PJM’s monthly TEAC meetings, a process that is not user friendly. Many people had difficulty signing up for TEAC meetings, and even when they managed to crack that nut, they were faced with sitting through many hours of the meeting waiting for an opportunity to comment, as the discussion of these new projects was always the last item on the agenda. I asked that PJM accept written comment from the public instead. PJM staff either did not answer my emails, or took weeks to do so. By the time PJM staff finally agreed to accept written comments, they told me we needed to hurry up and submit comments because the contractor was finalizing its constructability report. PJM staff managed to delay long enough to prevent all but the most determined commenters from weighing in. This is not an open and inclusive stakeholder process. In fact, it thwarts stakeholder participation.
Once the constructability studies were completed, PJM staff refused to share them, preferring to share only a table with risk determinations, and not the considerations that went into them. It appears that even that table has been manipulated to change the results presented from meeting to meeting, with risk determinations changing without notice or explanation. I believe that the constructability studies are just as manipulated as the rest of PJM’s process and urge the Board of Managers to review them carefully. PJM has recommended some of the riskiest projects for the Board’s approval. Someone needs to ask them why.

Local impacts
The West project in Jefferson County, WV was presented as a preferred solution submitted by NextEra Energy Transmission to wreck and rebuild an existing 138kV line underneath a new 500kV transmission project. As proposed, this project would expand the existing easement and construct new, larger lattice towers. It was stated that this project would deviate from the existing 138kV easement in certain areas and create a completely new easement for the new 500kV line. This proposal was never accurately represented on PJM’s maps, which characterized the entire project in Jefferson County as brownfield. At the Oct. 31 TEAC, PJM staff reassigned the project to FirstEnergy, without explanation. We in Jefferson County cannot determine how FirstEnergy will approach it, how much existing easements must be expanded, or where new easements are expected to go. FirstEnergy has been awarded a project it can create in the future to suit its needs, not one that has been properly evaluated and shared with the public.
The existing FirstEnergy 138kV transmission line running across Jefferson County from west to east has been in place for decades. In some areas, it parallels an existing 500kV line owned by Dominion that was rebuilt, completely within the existing easement, around 2012. Since the original construction of the lines on this combined right-of-way decades ago, new development has been built bordering it, limiting the ability to expand without causing considerable destruction of the built community. The landowners along the easement don’t consider this easement expansion and addition of larger structures to be brownfield development.
FirstEnergy’s Transmission Rights-of-Way Restrictions prohibit the following items in its easements: buildings, lighting fixtures, signs, billboards, swimming pools, decks, flag posts, sheds, barns, garages, playgrounds, fences or other structures. As well, septic systems, leach beds, and/ or wells are not permitted within a FirstEnergy transmission right-of-way. Expanded easements will undoubtedly run into these structures on adjoining property, requiring their removal. Depending on the size of the lot, it may not be possible to move or reconstruct them on the remainder. Expanding the existing easement will cause considerable damage to host properties.
Several new utility-scale solar generation facilities have been approved adjacent to the existing easement, along with an interconnection to the 138kV line. Some of these facilities are currently being developed, with panels constructed directly adjacent to the existing easement. Depending on the expansion of the easement, many brand new panels may have to be removed. In addition, the existing 138kV line will have to be taken out of service for extended periods of time to allow for the demolition and rebuild. When asked how these generators would be able to transmit the energy they produce while the transmission project is offline, PJM staff did not have an answer.
During its Oct. 3 TEAC, PJM staff indicated that they had failed to recommend certain proposed projects due to historic opposition to a previous transmission project in the same area (TrAILCo). However, PJM’s consideration of historic opposition was not applied equally to other areas that have successfully opposed new transmission in the past. Jefferson County formed vehement and entrenched opposition to the PATH project between 2008-2012. That opposition was a factor in the PATH’s project’s ultimate cancellation by PJM. The proposed PATH project used the exact same route through Jefferson County that is now being recommended for PJM’s new 500-kV project. A dozen years is not long enough for impacted communities to forget what happened last time. The only difference between the TrAILCo opposition in Virginia in 2007 and the PATH opposition in West Virginia in 2010 is the deep pockets and political connections of the opposing community. Is PJM afraid of engaging important, well-funded opposition in one state, and instead preferring to engage less politically connected and funded opposition in another? This is the epitome of environmental injustice, where disadvantaged communities are expected to accept damaging new infrastructure over and over again.
The proposed 500-kV project in Jefferson County is not on a direct route to the data centers in Northern Virginia that need a new power supply. Instead it is an unnecessary and destructive diversion that seems to capitalize on an existing transmission line crossing of the Appalachian Trail near the Virginia border. If not for that existing crossing, a more direct route for this project could be utilized. Jefferson County is being sacrificed to prevent a new crossing over the Trail even being proposed. Perhaps PJM believes that it will attract less opposition by destroying Jefferson County than it would for designated entities to ask the National Park Service to permit a less costly and less invasive new crossing further south. We in Jefferson County object to having this project cross our county at all.

​Conclusion
I ask that PJM’s Board of Managers short-circuit PJM staff’s double-time march toward approval of these new projects on December 11 and allow additional time for meaningful public consultation and comment carried out through a user-friendly process. In addition, I ask that PJM present true and correct information about these projects, and their intended routes and risks, to both the public and the Board of Managers before approval. Please do not approve the recommended 2022 Window 3 projects on December 11.
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PJM's Constructability Farce

12/1/2023

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Constructability?  Is that a word?  My internet spelling police hates it, but constructability is defined as:
Constructability (or buildability) is a concept that denotes ease of construction. It can be central to project management techniques to review construction processes from start to finish during pre-construction phase. Buildability assessment is employed to identify obstacles before a project is actually built to reduce or prevent errors, delays, and cost overruns.
PJM loves its constructability analyses to select a project from a pool of many options.  PJM pretends it's all so scientific and dependable.  But, is it really?

Here's PJM's Constructability and Financial Analysis Report.  I didn't expect it to be anywhere near correct or accurate, and I wasn't disappointed.  It's completely illogical to the point of demonstrating bias.  Why is it that PJM has selected some of the most risky projects to recommend for approval by its Board of Managers?  Here's what I mean (see page 115 of the report for larger image):
Picture
Out of this "west" group, PJM has selected the riskiest project, Proposal 853.  853 has two "high" risks, two "medium-high" risks, and two "medium" risks.  It's the riskiest one in the table.  So, maybe it's about costs?  Proposal 853 costs $1,195,240.  It's still more than the cost of Proposal 904 at $1,122,400.  It can't be based on price.  Just what DID motivate PJM to select 853 instead of 904 or one of the other projects on the table?

What is proposal 904?  It's the building of a new 765kV transmission line through a section of central Virginia.  904 connects the data centers to a huge inventory of fossil fuel generators in the Ohio River Valley using AEP's 765kV transmission network.   Significantly, proposal 904 keeps all the transmission necessary to serve Virginia's new data center build in Virginia.  The other proposals inflict the burden of serving Virginia's data centers on other surrounding states.  Keep that in mind as we examine these two competing proposals as PJM did in its Constructability report.

Project 853
Overall, the ROW risk for the new West cluster transmission line components in this proposal is medium-high to high, as the proposed new transmission lines are routed parallel to an existing ROW for majority of their alignment. 

Environmental Risk Analysis
46a – 502 Junction to Black Oak OH 500 kV Line
Route crosses West Virginia and MD Department of Natural Resource (DNR)-recognized public lands and is also within a short distance of residential areas.
4CA – Black Oak to Woodside OH 500 kV Line
Route crosses through the Appalachian Mountains and intersects with VA Natural Heritage easements.
10C1A – Woodside to Gant (Segment 1) OH 500 kV Line
The proposed route for this line segment goes through several national scenic and historic trails (Harpers Ferry National Historical Park and the Appalachian Scenic Trail), and intersects public lands and conservation easements. This may require permission from the National Park Service (NPS) and require an Environmental Assessment (EA) pursuant to the National Environmental Policy Act (NEPA) to analyze the impacts to the environment and park resource, which could be a lengthy process. This route is also within a short distance of residential and commercial areas.
10C3 – Woodside to Gant (Segment 2) OH 500 kV Line
The proposed route for this greenfield line segment goes through highly developed residential and commercial developments, as well as state and local conservation easements. This route also crosses the Washington & Old Dominion (W&OD Trail), a regional park in northern Virginia. There is significant risk of public opposition to the proposed route, which may lead to rerouting this segment along the existing corridor from Doubs to Goose Creek.

Overall, for Proposal 853, medium-high constructability risks are assessed for the proposed line routes due to anticipated lengthy regulatory process, potential public opposition, construction difficulty, environmental constraints and property acquisition, which may have significant impacts on the cost and schedule for the proposed project.

Transmission Line Risk Analysis
Significant engineering and construction challenges are anticipated for the proposed lines to construct a total of 167 miles of new transmission through four states and will require parallel crews and construction where possible to mitigate schedule challenges that will be introduced by the anticipated lengthy permitting and land acquisition process.
For the rebuild portions of the proposed line routes, there are challenges with existing overhead transmission infrastructure components needing to be removed/salvaged before construction of proposed brownfield lines can commence, and potential design and ROW limitations for reuse of existing infrastructure/assets.
Other medium risks for this project involve the existing facility outages that will be necessary for the project, particularly for the line rebuild and substation upgrades. 

Schedule Review
The proposed in-service date of June 2027 is very aggressive for the proposed scope of the project considering the significant permitting and land acquisition challenges associated with the proposed 500 kV greenfield line routes through four states. Overall, the schedule risk is considered medium-high. 
Project 904
Environmental Risk Analysis
Joshua Falls-Yeat 765 kV OH Line
The proposed line route has the potential to impact environmental and cultural resources including: the Southern Albemarle Rural Historic District, a FEMA High-Risk Flood Zone, wetlands and several waters subject to USACE Section 10 permitting, the most significant being the James River. The route also intersects local conservation easements and appears to co-locate with pipeline ROWs.
Warrenton-Wheeler 230 kV OH Line
The line crosses woodland, residential and agricultural parcels in Fauquier and Prince William counties in Virginia. The route intersects local conservation easements and potentially impacts environmental resources such as Auburn Battlefield Historic District, flood plains and wetlands.
There are medium constructability risks assessed for the proposed line routes due to anticipated lengthy land acquisition process, potential public opposition and environmental constraints, which will have impacts on the cost and schedule for the proposed project.
Transmission Line Risk Analysis
Transource has an optimistic schedule for several aspects of this component and would require a near perfect execution to maintain the proposed in-service date. Given the scale of the component, a 135 mile 765 kV line with everything from permitting to land acquisition to construction poses a risk for delay, the most critical being land acquisition.
For the 230 kV developments, Yeat-Clover Hill and Warrenton-Wheeler, these facilities will utilize BOLD (Breakthrough Overhead Line Design), which is a structure family developed by AEP. The design features a monopole structure with two arched crossarms to hold two circuits in a delta configuration. Benefits of BOLD include increased line capacity with lower-profile structures. However, utilizing this structure family poses risks to the schedule, specifically procurement of the arched crossarms, construction and maintenance of a non-typical design.
​
Schedule Review
This proposal includes 765 kV substation and transmission line construction, as well as utilization of BOLD (Breakthrough Overhead Line Design) technology for the greenfield 230 kV lines. The sum of all components is a very aggressive undertaking to be completed within the proposed schedule. The primary risks for this proposal are related to the magnitude of the scope of work, procurement and construction of 765 kV equipment and BOLD structures, state permitting and land acquisition for both the 765 kV and 230 kV developments. These all pose a medium-high risk to the December 2029 in-service date proposed by Transource. 
Project 853 has medium-high constructability risks, while 904 has medium constructability risks.  Gee, no help there either.  904 is cheaper and less risky, but PJM still selected 853.

And then there's this tidbit... did you catch it the first time you read it?  
There is significant risk of public opposition to the proposed route, which may lead to rerouting this segment along the existing corridor from Doubs to Goose Creek. 
PJM KNOWS this project isn't going to happen the way it was proposed and recommended for approval.  PJM is already anticipating so much opposition to the new greenfield segment in Loudoun County that it will have to abandon this plan and move the proposed new 500kV transmission line over to an existing corridor between Doubs and Goose Creek.  What is that corridor?
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The 853 project in Loudoun is represented by that green line.  The Doubs corridor is represented by that roughly parallel yellow line to the east.  Sounds like a solution, you think?  Think again!  PJM has also recommending work on the Doubs-Goose Creek corridor to add another 500kV line to its existing 500kV and 230kV lines.  In order to squeeze another 500kV line in there, PJM proposes to rebuild the existing 230kV line as a double circuit 230/500 kV line, and then add a second 500kV line.  Moving the 853 project over to the Doubs corridor would add a THIRD 500kV line to that existing corridor.  Would that be a double circuit 500/500 kV, in addition to a 230/500 kV double circuit?  Or would there be one 230/500 kV double circuit, and two separate 500 kV lines?  Either way, it will require significant expansion of the current easement through a heavily developed area of Frederick and Montgomery Counties (Maryland) and construct an unimaginable amount of power in that corridor (three 500kV circuits + one 230kV circuit).  Chances of success on this idea rate right up there with the survival of a snowball in Hell.  Which area is capable of forming bigger opposition?  Loudoun County or Frederick/Montgomery Counties?  Personally, I think it's a tie.  Either one is going to kill this project dead.  Remember, it's not about fighting each other to push the project off onto someone else, it's about stopping the bad project altogether.  Nobody wants this anywhere!

So, what did we learn from PJM's constructability analysis?  Not much.  PJM did not examine the gray areas of opposition that I did.  PJM pretty much ignored the possibility of opposition derailing their plans.  Dismissed!

But, we're not going away.  In fact, we're only going to get stronger.  I predict that this project will NEVER get built.  Maybe PJM should go back to the drawing board and take another look at project 904?  Why did they dismiss that project anyhow?  PJM never actually says.  In fact, after reading all of PJM's excuses, err I mean analyses, I came away more convinced than ever that this whole thing is a farce.  Some of the excuses for not selecting a project were so ridiculous, such as -- we didn't select this project because we selected a different project.  That's not a REASON for making a project selection.  I also got the idea that PJM is absolutely terrified of rich people opposition in certain areas of Northern Virginia.  PJM has bowed down to the wealthy and privileged due to their bad experience trying to route the TrAIL project through those areas.  PJM thinks it's a better idea to route its projects through disadvantaged areas that can't fight back (or so they think).  That kind of thinking is outrageous in this day and age of environmental and energy justice reform.  Add in the fact that PJM's new transmission lines are nothing but extension cords importing dirty, delicious, coal-fired electricity out of West Virginia and Pennsylvania and you've got a project idea that is dead on arrival when asking for federal help.

Stupid, stupid, stupid, on top of dumb, dumb, dumb, PJM!  It's obvious PJM has another agenda at work here and it's not providing needed electric service at the lowest cost.  Let's hope the PJM Board of Managers examines this farce carefully before making its decision on December 11.
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PJM Thinks It Has You Handled

11/30/2023

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PJM Interconnection has never been good at interacting with the regular people its projects impact.  Part of the problem is that the place is chock full of engineers and socially inept geeks, and the other part is that they think they don't have to explain themselves to you or anyone else.  Back around 2008, during the PATH transmission line fight, some public relations guy from PJM named Kerry Stroup told a local reporter here that "PJM answers to no one."  But PJM is NOT an omnipotent dictator.  PJM answers to the Federal Energy Regulatory Commission.  All the power PJM possesses comes courtesy of FERC.  If PJM doesn't follow its own FERC-approved planning rules, anyone can file a complaint at FERC.

After decades of digging a moat around itself in order to keep regular people out of its planning process, PJM's efforts have failed and they are now positively terrified of the ruckus you're about to cause.
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Public relations has never been PJM's strong suit.  In fact, PJM's public relations effort has been almost non-existent.  PJM depends on the utilities it orders to build the projects to interact with the torches and pitchforks crowd later on, after there's no chance to influence the plan.  But now, because impacted people have found out about PJM's plans before the projects have been awarded, PJM has made a feeble attempt to inform you about its "role" in ordering the new transmission projects that concern you.

Here's PJM's recently released Role in Regional Planning/2022 RTEP Window 3 document.  You are supposed to read it and accept it, even though you may not agree, and even though PJM may have left out some important things.  Here's PJM again telling people that it answers to no one and that PJM must build these things ASAP or your lights are going to go out.  It's going to say the same things to your state utility commission when it appears as a witness for the utility that is assigned to build the project.
Our analysis shows without doubt that there are going to be real reliability impacts without further transmission reinforcements. These solutions are required to maintain the reliability of the system. If the transmission is delayed, load has to be dropped. We currently don’t have anything in the new services queue planning to come online in time. We are working with Talen Energy, the owner of Brandon Shores, on keeping those units in service past their proposed deactivation date of June 1, 2025, in order to ensure reliability. 


PJM may provide supporting evidence on the need for a project from the perspective of grid reliability to help local officials better understand the project and its impacts. 
Think about that... PJM says it cannot deny service to a new customer (data centers) but if new transmission to serve these customers isn't built on PJM's timeline, then "load has to be dropped."  In other words, PJM will shut off service to certain customers.  You can bet it won't be the data centers.  So what PJM is really saying is that it is going to serve the new load and drop the old load.... unless you gladly welcome new transmission across your property, you selfish NIMBY.  Kind of makes your head hurt, right?  Remember, I said that PJM lacks public relations skill.

Here's the real answer that PJM isn't telling you... when a new customer asks the local utility for new service, the utility could certainly build new generators to produce the electricity for the new customers.  Building new generation is something that the state could require the utility to do.  Let's use Dominion as an example here because Dominion is the utility that serves the data centers.  Dominion could decide to build a new generator (or generators) near the data centers and ask the Virginia State Corporation Commission to approve it and assign costs to Dominion's customers.  But, with Virginia's "clean energy" goals enshrined into law, the chances that the VA SCC would approve a big, new baseload generator that could satisfy the data center's insatiable thirst for electricity are slim.  Nobody wants a new electric power plant in their neighborhood and solar, wind and other renewables can't supply the kind of on demand 24/7 power needed for data centers.  So Dominion and the Commonwealth of Virginia simply shrugged and passed the buck to PJM to find a solution to the reliability problem the new data centers have caused.  And this is the result.  You probably didn't envision this when Virginia passed its clean energy laws, but this is what happened because Virginia passed environmental goals that were NOT achievable when combined with the building of new energy-intensive data centers.  This is Virginia's problem and it's about time they own it, don't you think?

PJM handled the hot potato it received according to its existing rules.  PJM did not acknowledge that this is a new problem caused by state clean energy laws and out-of-control building.  PJM pretended that it was a transmission problem, not a generation problem.  Therefore, PJM sought out any usable generation in its region to solve Virginia's lack of power and designed new transmission line extension cords to plug it into the data center load.  PJM cannot order new generation to be built, it can only order transmission.  Therefore, when the only tool you have is a hammer, every problem looks like a nail.  Virginia could order new generation, but it chooses not to because new generation could make it impossible to achieve its clean energy goals.  Even the Federal Energy Regulatory Commission recently questioned whether new infrastructure caused by energy policies of certain states should be fully paid for by those states.  If Virginia had to pay for the entire $5B cost of this new transmission, perhaps building generation might be a cheaper alternative.  But Virginia thinks it can do it cheaper by choosing transmission that is cost allocated to other states that will not benefit from the data centers or clean energy laws.  

Ten years ago, PJM's independent Market Monitor suggested to PJM that it create a process by which new transmission is forced to compete with new generation to evaluate who would pay the costs and accept the risks of each alternative.  If PJM had only listened to the advice of its own expert, we'd be having a very different conversation right now.  It wouldn't sound like PJM's "Role" paper, it would sound more like this blog.

So, what can you do to change PJM's preferred plan?  The document gives you several options in the last couple of paragraphs.  The first is to participate in PJM's Transmission Expansion Advisory Committee meetings.  Been there, done that.  It's frustrating and exhausting.  At every turn, you are faced with the virtual moat PJM has constructed around its processes designed to keep regular people out.  PJM wants to make it really hard on you to participate.  If you do manage to get in, share your thoughts, and not give a damn what PJM thinks about you, prepare to be thwarted at every turn.  This is what many of us have experienced since August of this year.  The TEAC process for these projects is done.  PJM has made its recommendations despite everything that was said in its meetings.  Let's move along.

PJM's second suggestion is to send your comments to its Customer Service and Planning Departments.  Don't waste your time here, either.  PJM says it will "compile" these comments for the Board of Managers' perusal.  In other words, PJM will sanitize your comments so that they support its recommendations.  PJM only wants you to communicate with its Board of Managers through a filter it controls.  You might as well not even bother.

The third option is the one you should use.
Any stakeholder may also provide written communication directly with the 10- member PJM Board on issues regarding PJM markets, operations or planning. This communication will be made public, consistent with rules related to “ex parte” communications as outlined in the PJM Code of Conduct. All such communications should be sent to the PJM Members Committee Secretary ([email protected]), who will ensure delivery to the Board of Managers. Notice of Board communications and documents are posted and available on the Board Communications page of PJM.com. 
Write directly to the Board.  Don't let PJM's TEAC filter your comments.  All that nonsense about "ex parte" communications is meant to scare you away from this option, but it doesn't mean anything.  So what if your comments are made public and posted on PJM's website?  SO WHAT?  Complete instructions for composing your letter to the Board of Managers can be found here.  Remember, you are writing to the Board -- Dave Anders is just the mailman.  Do not address your comments to Anders.

Deadline for comments to PJM's Board of Managers is Monday, December 4 (one week before the Board meets to consider approval of the projects on December 11).  PJM "forgot" to tell you about that in its "Role" paper.  Another Freudian slip that can derail your efforts.  It seems that PJM is more about trying to keep people out of its processes than it is about inclusion.  PJM doesn't care what you think and is going to do what it wants despite your best efforts.  If PJM is trying to steer you away from a letter to the Board of Managers, then you can bet that's your best option.  Maybe PJM is a little transparent after all... but not in a good way.
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Your Lack of Planning is NOT my Responsibility!

11/13/2023

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PJM Interconnection's solution to 2022 Window 3 transmission needs is comprised of a collection of new and upgraded 500kV transmission lines, along with a number of 230kV new lines and upgrades.  Why does this matter?  It's all about who pays.

PJM will assign project costs to different subregions of its territory according to its existing FERC-approved cost allocation rules.  As noted in a recent FERC Order, these rules are:
PJM utilizes a hybrid cost allocation method, which the Commission found complies with Order No. 1000, for Regional Facilities and Necessary Lower Voltage Facilities that address a reliability need.  Under this method, PJM allocates 50% of the costs of Regional Facilities or Necessary Lower Voltage Facilities on a load-ratio share basis and the other 50% based on the solution-based distribution factor (DFAX) method.  PJM allocates all of the costs of Lower Voltage Facilities using the solution-based DFAX method.  Cost responsibility assignments pursuant to the Order No. 1000-compliant cost allocation method are included in Schedule 12-Appendix A of the Tariff. 
500kV lines are "Regional Facilities".  It is likely that the 230kV improvements will be "Necessary Lower Voltage Facilities."  Therefore, 50% of the cost of these new lines, estimated at $5.4B, will be allocated to ALL customers in the PJM region based on their load-ratio share.  The load-ratio share, in layman's terms, is the amount of PJM's total load used by each sub-region. Everyone who pays an electric bill in PJM will pay for their share of $2.7B of new transmission that is only necessary because of the building of new data centers in Northern Virginia and the closing of fossil fuel generation made necessary by the clean energy laws of certain states.  Although the reason for the lines is caused by only a portion of the region, everyone pays.

The other 50%, or $2.7B, of the costs will be allocated using the DFAX method which, in layman's terms, would be the specific sub-regions who use the new facilities.

This is set in stone and it cannot be changed unless PJM petitions FERC to change its cost allocation rules, or FERC takes the initiative to begin a proceeding to investigate electric rates that have become unjust and unreasonable. 

This cost allocation for PJM's new projects is not fair.  However, there is nothing you can do about it.

In a recent case, PJM filed a cost allocation document for recently approved projects intended to solve the closing of the Brandon Shores coal-fired plant in Baltimore.  Most of the cost was allocated to the sub-region around Baltimore that would use the new facilities, with some smaller portions assigned to other sub-regions.  Maryland regulators didn't like this.  They thought PJM should have found other solutions to the generator closing instead of a quickly approved transmission plan that cost nearly a billion dollars.  The Maryland regulators filed a protest in PJM's cost assignment FERC docket.  FERC said that since the cost allocation PJM made was in accord with PJM's existing, FERC-approved cost allocation rules, there was nothing they could do but approve it.

However, something interesting happened there.  Commissioner Mark Christie, a champion for electric ratepayers, said it wasn't fair, although he was obligated to approve it.  You should read his Concurrence because it may be a harbinger of things to come.
PJM has told us that if we fail to approve those transmission projects in this RTEP driven by the closure of the Brandon Shores coal generating unit located in Maryland, the grid will likely suffer a severe voltage collapse in Baltimore and the surrounding zones, including Northern Virginia, the District of Columbia, Delaware and southeastern Pennsylvania. Such a result could be potentially catastrophic.
While these projects are very costly – and I take seriously the concerns expressed by the Organization of PJM States, Inc. (OPSI), Maryland Public Service Commission (MD PSC) and Maryland Office of People’s Counsel (OPC) – given this Hobson’s choice I concur with approving PJM’s RTEP filing.
While I concur, I note that this element of the RTEP filing raises more questions than it answers, and some of those questions are extraordinarily important.  
Although perhaps he did not find the cost allocation fair, Commissioner Christie chose to approve it because of the extreme risk of blackouts if the projects were delayed by a FERC investigation into the justness and reasonableness of PJM's cost allocation policies.

We are hobbled by PJM's bad policies and poor planning practices into a future that never allocates project costs fairly.  Will people complain about the upcoming cost allocation of PJM's 2022 Window 3 projects?  Absolutely.  But will FERC open an investigation, or will it be forced into another Hobson's choice?

Commissioner Christie shared his thoughts on how PJM's cost allocation rules have been rendered unjust and unreasonable by recent events.
Let me emphasize that the State of Maryland, within its sovereign police powers, clearly has the authority to mandate any particular mix of generating resources it prefers.  Maryland’s new climate law is well within its inherent authority to enact.  Such policies are for Marylanders to choose, not RTOs or FERC.  But if the resulting transmission projects under protest in this RTEP filing are caused more by Maryland’s policy choices than by organic load growth and economic resource retirements, then a salient question that may be asked is whether these transmission projects are more accurately categorized as public policy projects, essentially the same as the transmission upgrades caused by New Jersey’s offshore wind projects?
And if they are more accurately categorized as public policy projects, should such projects be regionally cost-allocated, potentially to consumers in Pennsylvania, West Virginia, Ohio, et al.?
A very relevant question that can also be applied to the current problem with PJM's 2022 Window 3.  Is the closing of more generation in certain states due to their climate laws, and the out-of-control building of new data centers that will only benefit one or two counties in Virginia, more of a public policy issue that should be paid for by the states/localities involved?  After all, it is their choice to put pressure on the amount of generation available in PJM.  Before passing laws that mandate the closing of existing generators, or before approving the building of new facilities that require extreme amounts of new electric supply, the states or localities responsible need to make sure that they still have adequate generation available to serve their load.  It is within their power to include a provision in their law that the closing of generators must be balanced with the building of new generators.  It is also within these state powers to make sure there is an adequate supply of generation in the state/locality to serve big, new electric customers like data centers, before approving them.  Instead, the states/localities are making these choices and leaving the consequences on the doorstep of others who have no vote on that state's policy choices.  This is not just and reasonable.  It's irresponsible.  It's selfish.  It pushes the consequences of a state's policy choices off on residents of other states.  In this same vein, do the voluntary policy choices of one state that requires new transmission also compel other states to use their eminent domain authority to take property from their state's residents to create easements for new transmission that serves the state making the selfish policy?  Why would I be asked to give up my property to build transmission that is caused by the building of data centers in Northern Virginia?

The "New Jersey" approach Commissioner Christie refers to is what's known as the "state agreement" approach to cost allocation.  It is a more recent construct that allows a state with a new public policy to voluntarily agree to shoulder all the costs of new transmission made necessary by their state policies.  This construct would prevent the unjust and unreasonable allocation of costs to states that did not cause the need for new transmission.  It's exactly where we find ourselves now.  The question is, would FERC open an investigation to correct PJM's current cost allocation for Window 3 to order it be allocated according to the public policy "state agreement" cost allocation approach?
It is ultimately the job of each state to ensure resource adequacy to serve its consumers, even in a multi-state RTO. ​
Amen, Commissioner Christie!  Perhaps if they did, they'd stop prematurely shutting down fossil fuel generators before replacement generation is available.  And perhaps they'd stop approving new data centers without any viable means of powering them.  Instead, it's been left on the doorstep of all the other states in the PJM region to pay for, and house, transmission only made necessary by the thoughtless politics of certain states and localities.  This is not just and reasonable.
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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.

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    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.

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