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The REAL End For The PATH Project Finally Arrives

1/17/2020

I first heard about the PATH Transmission project in the summer of 2008. It was a horrible, unneeded idea that eventually met its fate, shelved in 2011 and cancelled for good in 2012. Many considered that the end of the PATH project.

But it wasn't. A formal complaint about PATH's rates had been filed at the Federal Energy Regulatory Commission in January, 2011. I chose to stick with that complaint, even when PATH was no longer a threat. It's been a lot of work over the past nine years, coming in fits and starts.

We prevailed on our complaint, and PATH was ordered in 2017 to refund more than seven million dollars, plus interest and undue return it had collected for its extensive public relations campaign and lobbying carried out for the purpose of influencing the decisions of public officials considering the project's applications. The correct precedent was set, and utilities under FERC's rate setting jurisdiction may no longer collect these kinds of costs from ratepayers.

Done!

But, not really. Several more orders were issued since then, correcting PATH's refund filings. Even though ratepayers officially paid off all the PATH debt in 2017, PATH has still managed to collect several million dollars a year from ratepayers while it bumbled its way through the FERC Orders and made required compliance filings. I continued to keep an eye on what was transpiring. Sometimes the kids get out of control if they don't have a babysitter.

The twice-yearly rate filing phone meetings and data requests continued. And how much fun were those? Not much fun at all. I'm seriously over it. Twelve years after PATH began collecting its costs through rate filings at FERC, it's time to put this thing to bed. For good! We've all got other things to do.

So, is it January again? It seems like a lot of the PATH things happen at FERC in January. New year, out with the old. Yesterday, FERC issued its agenda for its January, 2020, public meeting. PATH is on it. All of the open PATH matters are on it. They'll be settled one way or the other next Thursday.

Nobody knows what to expect until the order is issued. But the fact that it ended up, once again, on a monthly meeting agenda indicates that the Commission sees some value in making this order more visible. The Commission issues orders every day, but only a handful are significant enough to end up on the monthly agenda, delivered before an audience in Hearing Room 1.

I can't wait! No matter what happens, I'm am truly thrilled to put PATH behind me, for good!

FERC gets a lot of rancor from the public and the industries it regulates. But, in this instance, FERC has done an outstanding job sorting through everything and meting out justice. The FERC employees I interacted with during this case have been fair, considerate, and dedicated. I had a great experience at FERC. I have faith that FERC works for for the citizens it serves.

Twelve years... the lingering life of a transmission proposal that was concocted in haste... and repented at leisure. The ratepayer gravy train will now finally grind to a halt.

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Transource Continues To Waste My Money As Hearings Continue

1/11/2020

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There. I fixed the headline for this article published recently.

There's absolutely no good answer to why Transource feels the need to award a construction contract for a project that hasn't been approved in either state in which it is proposed to be constructed. No good reason at all.

Maybe it's a PR stunt? Perhaps Transource wants to tell the PA PUC in its upcoming status report that it has awarded the contract for the project to a "Pennsylvania company" and created jobs in the state? Otherwise, it makes no sense at all, since Transource cannot put any shovels in the ground until it has its certificates. But what may be happening is stockpiling of materials and final engineering work for a transmission project that will never be built. Transource continues to spend buckets of ratepayer cash on their dead project. Every dime Transource spends will have to be repaid by electric ratepayers assigned cost responsibility for the project by PJM, plus annual return more than 10% until the sunk costs are paid off. We're talking tens of millions of dollars repaid over perhaps a 5-year period when the project is abandoned. Actions like this are why everyone's electric bills are so expensive. We've only recently finished paying off the quarter billion dollar sunk costs of the failed PATH transmission project that was never built. Gotta keep those dollars coming in for abandoned projects!

So, who got awarded the contract for a project that will never be built? Harlan Electric, which is supposed to be based in Harrisburg. But it's also based in Massachusetts and Michigan, and builds projects all over the place. If you think all the folks working on the project for the company are based in Harrisburg, you may not be correct. How many workers would be imported to construct the project? If all workers were local to Harrisburg, there would be no need for hotels with group rates, right? The workers could simply go home every night. Instead, Transource wants to hear from local hospitality folks who want to bid on supplying restaurants, catering, venue rental, and hotels with group rates. Sure sounds like support for a traveling minstrel show of transmission workers.

But it seems there is one company local to Pennsylvania (although not in the project area) that has been awarded a subcontract, according to the Waynesboro Record Herald.

Harlan Electric representatives are securing subcontractors and will be working with local contractors such as Newville Construction of Newville.

So, Harlan is just a general contractor who will be subbing the actual work out to other contractors? My, my, that sure sounds cost efficient! Everybody gets a piece of the ratepayer cash pie!

And where have we heard the name Newville Construction before?

I think it first came up in this video, where a farmer appealed to other farmers in the project area, telling them that the transmission project won't be a burden and that the construction company would leave their property in better condition than they found it. The farmer, Jim Shuster, didn't mention that he is also the President and Founder of Newville Construction. Of course, that's not relevant, right? It must have just been a happy accident that a company he owns, in addition to his farms, ended up with a construction contract, right? Of course, Jim wasn't paid "a plugged nickel" for his work in the video. That's what he said in this article.

"Jim spoke from his perspective as the owner of Eleven Oaks Farm on his experiences with utilities and agriculture. Transource has not yet made a selection of the construction companies that will build (the line), nor has it promised work to Newville Construction."
Shuster said that is the case. He said he was approached by the International Brotherhood of Electrical Workers to appear in the video and testify about his experience with power lines and agriculture. He doesn't understand the opposition to the power line. "I wasn't paid a plugged nickel for that," he said. "I was not promised a dime's worth of work for doing it."
The impact on the land is minimal, he said, and his company operates under the directive to leave the land in better condition than they found it, something that has earned the company awards and praise from conservation groups.
Transmission and Agriculture video.mp4
"We're not some Ma and Pa operation with a backhoe," he said. "We're a $30 million-a-year business."
He is angry with some of those who oppose the power line because, he said, they suggested that his farm is a hoax. About the opposition, he said, "It's one of the most hypocritical things I've ever seen." Unless those opposed to the transmission line have their own power plant, he said, the electricity they use flows through a power line on some other farmer's property.

"I frankly don't understand what their problem is with it," he said.

Well, serendipity! What a fortuitous event! What are the chances? Wish I could take those chances to Vegas! Jim wasn't promised a thing in exchange for making that video. He only did it as a favor to the union. And by a rare stroke of good luck, he ended up with a contract to work on the proposed transmission line!

I wonder if Jimmy Hoffa knows anything about this? Maybe I can contact him via seance? The union is surely involved somehow.

“Anytime jobs are created, it’s a win,” said Bernie Kephart, business manager for IBEW Local 126. “Our workers earn family-sustaining wages building the infrastructure that supports our daily lives. We’re proud to build infrastructure that saves customers money and reinforces the grid against power outages in Maryland and Pennsylvania.”
“We support clean, safe and affordable power,” said William C. Tipton Jr., business manager/financial secretary for Maryland IBEW Local 70. “Any conversation around energy comes to a quick halt if we do not have the transmission infrastructure to transfer that power to all who need it.”

Wait a tick... it has not been determined that the IEC will save customers money or reinforce the grid against power outages in Maryland and Pennsylvania. It also has not been determined that the IEC would provide clean, safe and affordable power. The only ones who can make this determination are the Pennsylvania PUC and the Maryland PSC. Neither one of these agencies have made their determination yet. There's still a long slog ahead, and there's still opposition from state agencies who protect customers, as well as opposition from landowners in the project area. The jury is still out.

Jobs aren't everything. Creating jobs just for the sake of having jobs is a waste of money. My money, your money, electric customer money.

Local companies contracted by Transource also completed much of IEC’s geotechnical survey work, which concluded last year.

Right... and much of that money was wasted when the original eastern route was completely scrapped in favor of building the connection on existing right-of-way. It's not like using existing infrastructure was an idea that came out of the blue after the work was completed. Opponents had identified existing resources and asked to use them from the very beginning, before one penny was wasted on geotechnical work.

Waste, waste, waste.

But, hey, now that Transource has awarded all its construction contracts, perhaps we can get a better feel for how much this project is actually going to cost? With all these contractors, subcontractors, and hotel venues, maybe it would cost more than has been estimated? There's no cost cap on this project. The more AEP (Transource) spends, the more it makes! Perhaps that's why they're still moving full-speed ahead on a project that has stalled in the regulatory process? Maybe they just want to pad their investment so they can recover it from us with interest?

Stop wasting my money, Transource!

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"Wolf!", Cried Sierra Club

1/2/2020

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Ya know how I suspect you don't have a cogent argument? You make crap up to try to scare people to support your position. And that seems to be what happened when the Federal Energy Regulatory Commission ordered a re-vamp of PJM Interconnection's capacity auction.

PJM's markets are a confusing mess that not a lot of folks understand. Regular people understand pretty much nothing about PJM's electricity markets that supposedly serve their electric needs and provide power at prices that save consumers money. That's what PJM says anyhow, and since most consumers don't even know that PJM exists in the first place, it's pretty much an "I don't care" situation. But, in the energy world, PJM's markets are a big deal, a real big deal. PJM's markets have been gamed and influenced to provide the most profits to energy suppliers forever. That's why PJM has a Market Monitor to keep an eye on things to try to outsmart the gamers.

Over the last decade, states who have authority over their own electric generation mix, have attempted to encourage the generation source of their choice by providing subsidies. But when those subsidies interfere with PJM's regional electric market, it becomes non-competitive. One time, a state wanted to provide subsidies to a new generator that made up the difference between the generator's revenue and the PJM market so that it could offer and be accepted into PJM's capacity market. The courts said that was not permissible. State subsidies cannot be tied to PJM's market. Since then, numerous states have found ways to subsidize their generation of choice without overtly tying it to PJM's market. But the subsidies DO affect PJM's market, making that generation source "cheaper" so that it can offer a lower bid into the capacity market because the state is covering some of the generator's costs.

You only need a rudimentary knowledge of how PJM's capacity market works to understand this. Capacity isn't electricity. Capacity is the ability to produce electricity when called upon to do so. Generators are paid for their capacity separately from the actual power they provide. Because PJM has a need for a certain amount of electricity to keep the power on, it has to know that it will be available. PJM sets its resource number for each year three years in advance, then holds an auction of sorts. Generators with available capacity submit sealed bids. PJM stacks the bids by price. It then accepts bids, starting with the lowest, until it get up the stack to the amount of generation that meets its resource requirement. All generators accepted in this process are paid the top clearing price. Say the generator supplying the last bit of capacity bid $50, that means that every generator accepted gets paid $50, even though they may have bid in at a lower amount. It pays to be a lower bid in the capacity market. A generator can provide a lower bid because it receives subsidies. Without subsidies, it would have to bid in at a higher cost, and that could mean that it doesn't clear the auction. It would also mean that the ultimate price for all the capacity would rise if all generators had to bid in at their unsubsidized cost. This subsidy gaming of PJM's market has been going on forever, but in such small amounts that it didn't really affect the market.

But in recent years, states have gone wild with the subsidies for renewables and other favored generation, such as nuclear. With all these new subsidies, the market price tanked and the unsubsidized resources were forced out of the market. Many have closed. A market made up of subsidized resources is artificially priced and not really a competitive market at all.

So, FERC has been trying to fix this. One fix is to strip subsidies from offered resources to make them bid in at a realistic price. That's what FERC did just before Christmas. It ordered PJM to revise its MOPR (Minimum Offer Price Rule) to nullify the effect of state subsidies.

And then all hell broke loose.

The self-serving environmental groups and renewable and other generators benefiting from subsidies freaked out. And this happened.

“Trump and FERC are selling us out to the fossil fuel industry. They are adding billions of dollars in subsidies for coal, oil, and natural gas at the expense of green jobs and our health. They will now be getting over $6 billion a year just from our PJM grid alone, in addition to $15 billion a year in direct federal subsidies and all types of indirect subsidies. These dirty industries cannot compete with cheaper and cleaner renewable energy, so they are looking for a massive subsidy at our expense. This will hurt green jobs and public health,” said Jeff Tittel, Director of the New Jersey Sierra Club.

Honestly, what rubbish!!! He says that FERC added billions of dollars of subsidies for coal, oil and natural gas. They did no such thing. That's an outright lie. FERC did not give new subsidies to any generators, it simply mitigated the existing subsidies for renewables and nuclear. If all generators exist on an even playing field, it is not instituting new subsidies. And then he whines about "federal subsidies." The FERC order didn't touch federal subsidies, like the production tax credit for new wind generators. FERC felt it had no authority to nullify federal subsidies, just state subsidies.

The environmental groups have been whining about subsidies for a number of years. As subsidies for renewable generators took off into a billion dollar industry, environmental groups chose to defend that by pointing to what it calls existing subsidies for fossil fuel generation. Try to have a debate with any cleaniac about renewable energy subsidies, and they deflect by claiming other generators are getting just as much in other subsidies. It's not true, but it serves to change the argument to one about dueling subsidies and away from public outrage at the juicy subsidies filling the pockets of renewable energy companies. There are no overt subsidies of fossil fuel generation that come even close to those provided by the federal government for utility scale wind and solar. Big Green insists renewable subsidies are no greater than those provided to fossil fuels.

But when FERC removed all state subsidies for all generators, Sierra Club whines that renewables are hurt by it. If the subsidies are equal, then removing them all doesn't change anything. Apparently there are more subsidies for renewables than there are for fossil fuels, or renewables wouldn't be hurt by their removal. Big Green's favorite argument has flamed out. It no longer has any relevance.

I'm going to guess that the Sierra Club guy crying about shameful giveaways didn't even bother to read the FERC Order before beginning to bellow. That's pretty shameful in itself. I actually did read the order, hard as it was to stomach, and I can't find any basis for the nonsense spewing from Sierra Club. What I find interesting is the whole state v. federal thing. If states are providing subsidies to certain generators, those subsidies are coming from state consumers and/or taxpayers. The subsidies are affecting a regional market, not just one contained within the borders of the state. So, if New Jersey subsidizes nuclear generators and that lowers the regional capacity market price, I would get a price benefit here in West Virginia. Thanks, New Jersey! And now, if New Jersey is still providing a subsidy to generators that does not lower prices in the regional market, and market prices go up, New Jersey citizens are sort of paying twice for the same subsidy. Maybe they should rethink their subsidy, instead of trying to visit it upon everyone else?

Some claim FERC's Order will cause a great exodus from PJM and its regional market. Buh-bye, don't let the door hit you on the way out. If a state wants to subsidize certain kinds of generation that fits with its political goals, then it needs to keep that subsidy within its own borders. Go ahead, subsidize what you want. That's a state issue. I could be selfish and parochial here, since New Jersey and other states are subsidizing the regional capacity prices I have to pay, and only worry about my own bottom line. But the continued (and increased) state subsidies are causing existing generation to drop out of the market as uneconomic. That's generation that we've all paid for over the years, replaced by new generation that we're all going to have to pay for over the next 50 years. At some point, this kind of a market is going to explode. Regional capacity prices will be pure fiction, totally influenced by individual state policies.

So, do we really need a regional capacity market? Do we really need to know that sufficient generation will be available 3 years from now to keep the lights on, or should we depend on state generation policies to provide adequate generation for their own state? Or, maybe we should just cross our fingers and hope the lights come on three years from now, when existing baseload generators are all gone and we're depending on a new crop of intermittent generators whose capacity factors are quite small? Remember, capacity is a generator's ability to generate power when called. Those coal and gas generators have high capacity factors because they can generate any time from stockpiled fuel. Wind and solar, however, have very small capacity factors because they rely on the vagaries of weather and sunlight to supply their fuel in real time. If we add huge battery capacity to create a stockpile, that has a huge additional cost. Because the capacity factors of renewable generators are so small, we need to hugely overbuild them to guarantee any amount of capacity. How would this end up being "cheaper"? State generation subsidies are merely skewing the market for now, with big problems down the road.

Let's see what FERC's Order does to PJM's capacity market, and if we're actually getting some surety from the "increased" costs it imposes. Today's prices aren't really lower, they're subsidized and being paid outside PJM's market through state subsidies. What if you added up the current capacity market costs and all existing state subsidies that will now be nullified? That's the actual true cost of capacity. This order won't so much increase prices as it will re-allocate who pays the cost of capacity.

The sky isn't falling. There's no slobbering wolf wandering through town. It's just Sierra Chicken Little and all his chickie friends telling us once again that the world is ending because they didn't get their way. Thank goodness there are energy professionals that actually understand these markets and don't base their decisions on a bunch of propaganda and whining.

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Maryland Office of People's Counsel Digs Into PJM's Magic Math

12/19/2019

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Earlier this week, a whole pile of testimony was filed at the Maryland PSC regarding the partial settlement that Transource engineered in the case of its proposed Independence Energy Connection.

We all know that PJM has been using magic math to alter the project's benefit/cost ratio in order to make it appear economic. But, what exactly has PJM done? The OPC's witness gets right to the point. In its latest iteration, PJM's B/C left something important out of its "base case" that calculated benefit. PJM has been inconsistent in evaluating the three separate projects it recently bundled into one aggregate project with a B/C of 2.25:1. When project 5E (the Graceton-Bagley rebuild) tanked below 1.25, PJM added the H-L project (Hunterstown-Lincoln) to its base case in order to raise that number to 1.8. PJM added H-L because it increased the B/C ratio for 5E.

However, when it came time to re-evaluate the Transource project, PJM took H-L OUT of the base case because that increased the B/C ratio for the Transource project. OPC's witness believes that the "benefits" of the Transource project will fall if H-L is included in the base case.

I believe that PJM should have conducted an evaluation to calculate the B/C ratio of the Reconfigured Project 9A with the H-L Project in the base case, consistent with its approach to evaluating Project 5E. Project 5E failed the B/C threshold in the latest reevaluation, but PJM repeated the analysis including the H-L Project in the base case because of its impending recommendation that the PJM Board approve the H-L Project. My understanding of the rationale for including the H-L Project in the base case is that with such a high benefit-cost ratio and a low total cost it is highly likely the H-L Project will be approved, and that project will impact the flows to Project 5E, making it more reasonable to review Project 5E with the H-L Project in the Base Case.
The Reconfigured Project 9A has a similar fact pattern, although the results are opposite directionally. The latest reevaluation of Project 9A passed the B/C threshold without the H-L Project, but it is reasonable to expect that, due to the proximity of the two projects, the addition of the H-L Project will alter the flows of power that produced the 9A benefits.
While we do not currently have all of the data needed to estimate the results of that case, it is possible that including the H-L Project in the Base Case will reduce the calculated benefits of the Reconfigured Project 9A.

You should carefully read this testimony.

Bravo, OPC!

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More Trouble In Transourceland

12/11/2019

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Remember last month when a PJM member challenged the benefit cost ratio for its troubled Transource IEC project? Apparently that scared PJM so badly that it hauled out its magic math calculator to once again massage the numbers to make Transource economically "needed."

A new PJM whitepaper claims the benefit cost ratio for IEC, combined with the rebuilds of the BGE Bagley-Graceton line and the MetEd Hunterstown-Lincoln line results in a benefit cost ratio of 2.25, well above the 1.25 limit. That is, for every dollar spent on these three projects, it will return $2.25 in benefit to consumers.

But that's an aggregate, where the more beneficial rebuild projects bolster the low numbers of the IEC. And then it goes into a whole big, scary scenario of what could happen if the IEC is cancelled entirely:

It is important to note that if Project 9A or Alternative Project 9A were to be removed from further consideration, PJM’s RTEP analysis has previously identified a number of reliability criteria violations starting in the 2023 study year. Some of these reliability criteria violations include conductor overloads on 500 kV transmission lines which, in PJM’s experience, are likely to be resolved only through the construction of additional greenfield transmission. Should these combinations of projects inclusive of Project 9A or Alternative Project 9A be removed from the RTEP, resultant reliability criteria violations would be identified during the 2020 RTEP analysis, and potential solutions to such reliability criteria violations would not be identified to the Board until late 2020 or early 2021. Furthermore, removing these combinations of projects from the RTEP would fail to address the congestion that would be re- introduced into South-central Pennsylvania and Northern Maryland. Any proposal window to address this re-introduced congestion would not be held until 2021, with solutions not likely to be presented to the Board until late 2021. In light of this timing, and based on the likely need for greenfield transmission, PJM predicts that new CPCN applications for not-yet-identified reliability and market efficiency drivers would not be filed until 2022 or 2023. Conservatively assuming one to two years for state siting proceedings, reliability and market efficiency solutions likely could not be constructed sufficiently quickly to remediate reliability criteria violations, and further would leave customers subject to significant congestion for a number of years to come.

Oh, what a complicated web we weave when first we practice to deceive! There's a whole lot to unpack here.
1. IEC would relieve looming (but vague) "reliability" issues that may crop up later, so let's go ahead and build it anyhow. You'll never be able to specifically identify the "reliability" issue that was solved, because it will never occur.
2. PJM has identified "conductor overloads" on some 500-kV lines that can only be solved by new greenfield transmission. Oh, baloney! PJM has used this excuse before as a reason to build the PATH 765kV transmission line 10 years ago. Turns out PJM was all wet... a rebuild of an existing 500kV transmission line was accomplished that increased the capacity of the line enough to obviate PATH. It's just not true that 500kV lines cannot be taken out of service for rebuilds. It happened, despite PJM's claims to the contrary.
3. It's going to take too long to come up with an alternative using PJM's competitive transmission process. Seems like this is YOUR fault, PJM! Meanwhile...
4. Consumers would suffer, horribly SUFFER, from extreme congestion while PJM's long-winded transmission competition process takes place. Except we learned recently that congestion in PJM is at a record low.

Now, why did PJM think it was necessary to include a paragraph of fluff arguing against cancelling IEC? Dr. Freud... paging Dr. Freud... PJM sure spent a lot of time defending against cancellation. Must mean it's a real possibility!

Nowhere in this white paper did PJM evaluate what may happen to congestion or benefit cost ratios if it only undertook the rebuilds by themselves. This is the six hundred million dollar question... Would the two rebuilds accomplish enough on their own? How much does IEC drag down the economic benefit of the rebuilds? PJM chose not to examine the elephant in the room.

Meanwhile, back at the ranch, one of the "beneficiaries" of the IEC project doesn't want to pay for it. The DC Office of People's Counsel recently filed a petition to intervene in the Maryland PSC case considering the IEC. The DC OPC has done the math (apparently using a calculator as defective as PJM's that came up with a cost of $170,915,03) and decided that maybe the cost is too great for DC's ratepayers. The OPC seems rather stuck on the cost of the western segment of the project, which it dubs "ICE West." I'm guessing OPC objects to paying $55M for a project located in Franklin County, Pennsylvania, located in the outer reaches of lower Slobovia, where no ratepayer from DC would dare to tread. Franklin County is nowhere near DC, so maybe they can't see any benefit from building a transmission line there.

Under the cost allocation formula attached as Exhibit B to the October 17, 2019 Petition
for Adoption of Settlement, PEPCO zone would be allocated Net Load Payment equal to 20.23% of the total costs for the Independent Energy Connection West (“ICE West”)
project under PJM analysis dated September 25, 2019. This represents a net present
value of $170,915,03, based on current assumptions.

District ratepayers represent approximately one-third of the load in PEPCO zone and
thus would be responsible for approximately one-third of any costs allocated to that
zone. Under current assumptions for the ICE West project, that would amount to a cost
allocation to District ratepayers of more than $55 million.

So, maybe this petition is sort of clueless, but Transource went apoplectic in its response to the MD PSC, cuing up the spurious excuses (nobody served them with the petition!) and avoiding the obvious blunders in the OPC petition. Again... where's Dr. Freud?

At any rate, this petition from one of the supposed "beneficiaries" of the IEC definitely complicates things at the MD PSC. Just when Transource thought it had slayed all the dragons in Maryland by paying people off with ratepayer cash... Maybe the smell of free money was so pervasive that they even got a whiff of it in DC? The ratepayer-funded jackpot line forms to the left... who's next in line?

Let's face it... the IEC project has outlived its usefulness. Opposition is a snowball, and it's rolling down hill. If PJM doesn't get out of the way, it's going to be crushed. It's time to abandon Transource IEC.

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PJM Market Monitor Recommends Market Efficiency Process Be Eliminated

12/3/2019

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Sadly, nobody listens to the Market Monitor. His job is to monitor PJM's electricity market to ensure its fairness and that it results in the lowest electric costs for consumers in the region. Why does PJM need a Market Monitor? Because, obviously, PJM cannot administer a fair market that benefits consumers on its own. PJM (100% funded by consumers) doesn't have to implement the Monitor's recommendations. The Monitor has no real power to enforce its recommendations. Only FERC can order PJM to take action, and it mostly just sits there and pats its Frankenstein regional transmission operator monster on the head.

So, what's the point of the Market Monitor? Right now, there is no point!! The Market Monitor doesn't care about utility profits or politics, it only cares about the electricity market, and it does so in completely mind-boggling ways most of us can never understand. Perhaps PJM and FERC should start paying more attention to the Market Monitor's recommendations so that they are implemented.

In it's most recent State of the Market Report (issued in multiple volumes quarterly, and then compiled yearly into a breathtaking volume that rivals War and Peace) the Market Monitor made this new recommendation:

Market Efficiency Process The MMU recommends that the market efficiency process be eliminated because it is not consistent with a competitive market design. (Priority: Medium. New recommendation. Status: Not adopted.)

That's something everyone can understand. Eliminate PJM's market efficiency process.

Just eliminate it. Get rid of it. Stop it! No more planning for new transmission projects for the purpose of "market efficiency." Coming from the Market Monitor, whose business is market efficiency, it's a stunning proposal. PJM's "market efficiency" transmission planning process is completely failing the consumers it's supposed to help.

Perhaps if PJM and/or FERC had been paying attention to the Market Monitor's recommendations regarding this PJM process over the past several years, elimination wouldn't be necessary. But PJM and FERC have completely ignored the Market Monitor and continued to support awful cost drains like the Transource Independence Energy Connection, and FERC even awarded incentives to the project that allows the company to recover every cent it's dumping down the IEC toilet, plus profit, even if it is cancelled. We're going to pay for this boondoggle, even when no shovel gets put in the ground. How's that for efficiency, folks?

The Market Monitor has a bunch of issues with PJM's Market Efficiency process. One recommendation that's been dragging along for years is that there is no process to compare new transmission to new generation to find the most efficient method to eliminate transmission congestion. Transmission congestion is a economic concept that occurs when the cheapest energy generated in a region cannot reach all the customers in the region. When that happens, the customers on the other side of the congestion point have to buy their electricity from other, more expensive, generators that can avoid the congestion point. Often, these generators are located closer to the customers who need the power. PJM's market efficiency process attempts to build new transmission to eliminate the congestion point, making any electron generated in PJM available to any customer in PJM. It's utterly ridiculous! Why use a tack hammer when a pile driver gets the job done? Building new generation on the other side of the congestion point also gets the job done. New generation may lower costs to these customers by increasing supply available. This is how PJM's markets are supposed to work! PJM can only order the building of new transmission, not new generation. The market (high prices) is supposed to provide the market impetus that spurs new generation builds. But if PJM orders and builds new transmission to eliminate the market effects of generation costs, that signal to build new generation never occurs. PJM short-circuits it with the only "solution" it has in its tool box. The Market Monitor wants PJM to develop a process to compare the cost of new transmission to the cost of new generation before ordering new transmission. Building new generation can be the cheaper solution. It also avoids burdening other customers with new transmission.

PJM has even gone so far as to have FERC okay a method that eliminates potential new generation from its market efficiency planning process. PJM likes to pretend no new generation will be built, ever, therefore it "needs" to build new transmission to solve congestion issues.

The Market Monitor also takes issue with PJM's benefit to cost ratio determination.

The MMU recommends that, if the market efficiency process is retained, PJM modify the rules governing benefit/cost analysis, the evaluation process for selecting among competing market efficiency projects and cost allocation for economic projects in order to ensure that all costs, including increased congestion costs and the risk of project cost increases, in all zones are included and in order to ensure that the correct metrics are used for defining benefits. (Priority: Medium. First reported 2018. Status: Not adopted.)

There's a lot more to it, but I'll cut to the chase. PJM's current process only counts the "benefits" of reduced electric prices for the set of customers on the other side of the congestion point when determining "benefit." Unfortunately, eliminating congestion with transmission has certain side effects, like increasing prices to other customers who weren't experiencing congestion. Congestion can never be entirely eliminated, it can only be shifted around. Opening new pathways for electricity to flow changes supply/demand scenarios elsewhere, such as the Transource project, which will increase costs for Pennsylvania customers by hundreds of millions of dollars by draining electricity out of their well-supplied market. PJM should subtract the costs to other customers from the "benefits" to the customers who "need" the transmission project before comparing benefits to the cost of the transmission project. PJM's current process of ignoring cost increases in other parts of its region is skewing its cost/benefit calculations.

There's lots more in the report, but it's kind of hard to swallow for regular folks. Enter at your own risk! Even I can only process certain parts, but they are a refreshing voyage compared the the mountain of hubris and waste PJM produces in any given year. The Market Monitor is different. He's your watchdog for the PJM shenanigans that go on routinely.

In another section, the Market Monitor reports that transmission congestion has been reduced to its lowest level in 10 years. But we haven't built the Transource IEC yet! Is IEC really needed to relieve congestion? Numbers don't lie.

When is PJM going to listen to the Market Monitor?

More importantly, when is FERC going to pay attention?

Why are we spending all this money on the Market Monitor's expertise and advice, when nobody listens to it? Maybe the ratepayers should take up their own collection to buy the Market Monitor a uniform, some handcuffs, and a studded billy club and encourage him to enforce his recommendations? I'm in for $5.

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Transource IEC No Longer Meets PJM Benefit Cost Ratio

11/19/2019

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It was bound to happen. The Transource IEC has tanked and fallen below the benefit to cost threshold allowed by PJM. The sooner PJM admits this and abandons this project, the cheaper it's going to be for ratepayers. We're all on the hook for the cost of the project, so the sooner they quit spending money on it, the better off we'll be.

PJM is still trying to pretend that the IEC maintains an acceptable benefit/cost ratio, but it got the stink eye from someone who sees through all the baloney at a recent Transmission Expansion Advisory Committee meeting. Who would you rather believe? An independent member with no stake in the project, or PJM's assurances that we should blindly trust their magic math?

RTO Insider reports that PJM's analysis of the reconfigured Transource project was challenged by Sharon Segner, vice president of LS Power, at last week's TEAC.

Transource Energy’s alternative configuration for its Independence Energy Connection project doesn’t pass PJM’s cost-benefit test, LS Power said last week.

Sharon Segner, vice president of LS Power, told the Transmission Expansion Advisory Committee on Thursday that her company’s review of the newly proposed path for the eastern segment of the project only carries a benefit-cost ratio of 1, far below PJM’s 1.25 threshold.

Segner said PJM’s base case used to calculate the ratio doesn’t consider the impact of a nearby project that would alleviate congestion on the Hunterstown-Lincoln 115-kV line. PJM plans to present both projects to the Board of Managers in December for inclusion in the Regional Transmission Expansion Plan, Dumitriu said.

PJM pretends the IEC project has a 1.6 to 1 benefit/cost ratio. But Segner says that a different project, a rebuild of the Hunterstown-Lincoln 115-kV, will eliminate a lot of the congestion that Transource is proposed to solve. Now that PJM will be seeking approval for Hunterstown from its Board, the congestion solved by the Hunterstown project needs to be subtracted from the IEC's benefits. Once that is done, the IEC no longer meets the 1.25 to 1 minimum ratio.

Both of these projects cannot relieve the same congestion, it's one or the other. How much cheaper would it be for ratepayers to only pay for the Hunterstown rebuild? The IEC is a dead dog that PJM just won't bury!

We no longer need the eastern leg of the IEC. Without it, do we really need the western leg of the IEC? Since PJM has refused to separate these two geographically diverse segments into stand-alone projects, chances are that the western leg cannot stand on its own. It was always an "add on" to fulfill a transmission operator's eager dream to be able to connect the parallel west to east transmission lines by running a north-south line between them. Now that the congestion issues in the east can be solved by a simple re-build, the western segment has no basis. We're spending an awful lot of money trying to make this connection, including rebuilds of other lines that would support this north-south connection.

It's all a house of cards! So, PJM will be presenting both the reconfigured IEC AND the Hunterstown-Lincoln rebuild to its board at an upcoming meeting and seeking approval for both.

Meanwhile, PJM must update its RTEP to include the alternative plans for the IEC.

“We are going to give the board the complete picture of what’s going on,” said Ken Seiler, PJM’s vice president of planning. “There’s a lot of moving parts and a lot of variables, and we will make sure the board has the right information.”

Seiler added that “at some point,” the plans must move forward. “The area is congested and will be congested until we get some of these projects built,” he said.

Ya know, I seriously doubt that PJM will give its Board "the complete picture" when it makes it presentation in December. It wants to double count congestion relief benefits on each project. C'mon... it's one or the other, but not both. The PJM Board of Managers needs to start acting in the best interests of the ratepayers it works for, instead of its utility members.

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Was PJM Lying Then, Or Is PJM Lying Now?

10/24/2019

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PJM is all over the map about the value of the Transource Independence Energy Connection. Based on PJM's last testimony to the Maryland PSC, the recent re-route of the eastern segment would result in increased costs and decreased benefits. PJM said this when it was trying to avoid the eastern re-route.

Conceptual Alternative 3A’s costs are between $54 million to $94 million more than Project 9A’s most recent cost estimate;

As further explained in Mr. Horger’s Rebuttal Testimony, Conceptual Alternative 3A’s total estimated congestion benefits are approximately $267 million less than Project 9A’s total estimated congestion benefits;

Conceptual Alternative 3A has a lower Benefit/Cost Ratio than Project 9A (1.39 – 1.52 for Conceptual Alternative 3A compared to 2.17 for Project 9A).

The net benefit PJM calculated for the re-route at that time was $790M. It barely squeaked by the 1.25 to 1 required benefit cost ratio.

Now PJM says the re-route has a cost benefit of 1.66, or maybe it's 2.10?

Was PJM lying then, or are they lying now?

PJM is using a huge assortment of mismatched numbers to re-evaluate the benefit to cost ratio.

In Transource's settlement agreement with eastern route parties, it uses these numbers.

Transource MD, PPRP and Staff stipulate and accept that PJM's most recent market efficiency analysis of Project 9A with the Alternative IEC Portion, with the reconfiguration of the IEC Project (as set forth in this Settlement Agreement), reflects an overall benefit-to-cost ratio of 1.66 (based on total estimated project capital costs of $478,48 million) and a total 15-year net load payment benefit of $844.8 million.

These new numbers are supposedly based on a PJM analysis from September 25, 2019. What happened to the $790M estimate? How did it get to $844? Isn't that convenient? Suddenly, the eastern re-route provides more value now that PJM is desperate to get this project approved by hook or by crook. And it looks like the new costs of the project are more than PJM estimated. It went from a high estimate of $466M to an actual estimate of $478M.

But we're not done yet. PJM recently made a presentation at a meeting that claimed the cost of IEC, with the re-route, was $383.63M as of September 2019. And the benefits number has blossomed as the costs fell. The benefit number now is $855.19M. This now brings the benefit-cost ratio to 2.10. PJM claims these numbers are from a September 2019 re-evaluation.

Is this the same September re-evaluation where Transource got the numbers it plugged into its settlement agreement? How did the benefit magically go up $10M if PJM and Transource were using the same set of numbers? And why is Transource using a different cost figure (nearly $100M more) than PJM is using in its calculations?

What are the real numbers? We may never know because PJM seems to be using magic math to justify whatever it wants to do on any given day. Because PJM wants this project so badly, the re-route is suddenly cost effective, when it wasn't before. The benefit has ballooned to provide a new cushion for increased costs. Isn't that convenient?

Who believes PJM? Not me. They've contradicted themselves too many times over the life of this project. Either they were lying when they said the re-route couldn't work, or they are lying now when they say it could. I'm going to go with PJM was lying both times. This project can no longer be economic.

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Public Citizen Slapped Down by FERC After Filing Another Frivolous Complaint

10/20/2019

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It was inevitable. FERC slapped down another one of Public Citizen's frivolous complaints on Thursday. What a complete waste of time and money. And I'm not talking about Public Citizen's time and money, I'm talking about YOUR money wasted both by FERC evaluating the complaint, and PJM having to spend time responding to it. YOU paid for that.

Public Citizen was complaining that PJM was making political contributions and lobbying on the ratepayer dime. Sounds awful, right? However, it was nothing but a trumped up cloud of innuendo completely disengaged from FERC accounting policy and precedent. Like much of Public Citizen's FERC work, it was just crap on a self-aggrandizing bun of politics, liberally smeared with ignorance sauce. But, FERC is hard, you say, impossible to figure out, and therefore Public Citizen's effort was honest. No, it's not. I'm not even a lawyer, and I managed to figure out FERC. Sure, it took a lot of effort and time, something Public Citizen doesn't seem to want to invest, preferring its drive-by and dump strategy of being a persistent pain in FERC's ass. Fabulous. Whatever. But it's costing ratepayers a bunch of money responding to this unfounded crap.

So, why was Public Citizen's complaint denied? It claimed that PJM had made payments to both the Republican Governors Association and the Democratic Governors Association. Said associations being political associations therefore made the payments campaign contributions, according to Public Citizen. PJM answered that the payments were for membership in the associations so that PJM could attend association functions and interact with state officials to educate same. It's pretty cut and dried and rooted in precedent that's at least 15-years old. This particular argument has been done and overdone in ISO New England, 117 FERC ¶ 61,070 (2006). Regional transmission organizations may recover their informational and educational costs, even when it enters the realm of politics. A court has found such expenditures reasonable given the “potential impingement of government action on all stakeholders” and the need for legislative access to information regarding RTO activity. RTOs enjoy this status due to their lack of a profit motive. RTOs are profit neutral. There's no way an RTO can put extra money in its pocket through political activity. In FERCenese, "...because an RTO lacks a profit motive, it is easier to see that the ISO/RTO is pursuing activities that benefit its ratepayers, when the RTO seeks recovery of costs associated with state policy monitoring." Agree with it or not, it's set in stone. A lightweight like Public Citizen has no chance in hell of overturning it.

Public Citizen also whined about money paid to lobbying companies. FERC found the expenditures were related to educational and informational activities and therefore recoverable.

...the Commission permits RTOs to recover expenses related to RTO informational and educational efforts. Further, in affirming the Commission’s finding that ISO-NE’s external affairs expenses were recoverable, the court in Braintree explained, “it seems eminently reasonable to encourage legislature access to such an informational resource . . . [and] allowing recovery of [ISO-NE’s] costs in monitoring legislative activity, so that it may consider how such activity might affect its operations, appears quite reasonable.”

The only request Public Citizen made that could hold a tiny bit of merit was asking that PJM's political activities be publicly posted so that they may be monitored by stakeholders. Sunshine is a lovely thing! However, the Commission slapped that down too, saying that PJM's finance committee already combed through these expenses to make sure they were recoverable and that we should trust them. I'm not so sure about that, but it may have been more about Public Citizen's approach that caused FERC to shoot the messenger.

Another federal energy legal gaffe by Public Citizen comes to a close. Public Citizen published a whiny press release full of drama that no news outlets bothered to pick up, although a couple had run earlier articles touting Public Citizen's complaint. Blah, blah, blah... and then there's this:

FERC-regulated industries should understand, however, that FERC’s decision does not mean that all bets are off. The commission appears to acknowledge that ratepayer funds may not be used for political contributions. Unfortunately, however, the commission bought the assertion that the pervasively political governors’ associations are engaged in nonpolitical educational activities and that PJM’s payments related solely to those nonpolitical purposes. Utilities shouldn’t be misled into thinking they have free rein to use ratepayer funds for partisan political purposes.

Oh, for goodness sake! No utilities think that. They know better (much better than Public Citizen, apparently). Public Citizen acts like their actions here set some sort of precedent prohibiting the recovery of political expenditures. That precedent has been in place for more than 50 years! It was most recently enforced in Opinion No. 554 issued in 2017.

Public Citizen fails to understand the distinction between RTOs and utilities that FERC made in its order denying its complaint. Although an RTO may technically fall under some definitions of "utility," they're not actually a utility. They don't own any utility infrastructure, they merely operate the infrastructure of real utilities. Real utilities have profit motives that can be satisfied through political activities. RTOs do not. All RTO money comes from ratepayers. They have no other source of funds. There's no place to put any profits.

Utilities are already prohibited from recovering the costs of their political activities and rejection of Public Citizen's frivolous complaint didn't change that one bit. It's been tried before by much better lawyers than Public Citizen, based on the same precedent, and it failed. Spectacularly failed. No utility is going to use that decision as precedent to say that they believed FERC gave them permission to collect political activity costs from ratepayers. Honestly, Public Citizen's hubris is stunning.

Why does this matter? Because Public Citizen has also been engaged in a continual whine that FERC establish an office of the public advocate and provide taxpayer funding to "public interest organizations" like Public Citizen. They want to be funded by someone else to do even more of this worthless, costly filing of frivolous complaints. I object. I spent my own time and money on a successful FERC complaint. Nobody gave me one thin dime for what I did, however PJM ratepayers received more than $20M in refunds. I never asked for money. I did what I did because it was the right thing to do. And I found that utilities (not RTOs) actually DO wrongly recover the costs of their RGA and DGA memberships and lobbying expenditures. PATH was ordered to refund those to ratepayers, however even though utilities should be on notice as a result of that decision, I'm pretty sure they still do it. They do it because nobody is minding the store. FERC does not normally audit utility rate informational filings, and other utilities and state agencies don't have the expertise or funding to do it. Utilities get away with it all the time because no one investigates and challenges them. If, perchance, they do get the hairy eyeball from FERC, a customer, or ratepayer advocate, the utility simply claims it was a mistake and makes a refund. This game works because the chance of anyone actually discovering the utility "mistake" is slim to none and definitely worth the risk to the utility, who fattens its own bottom line the majority of the time.

Perhaps Public Citizen should spend more time investigating the political expenditures of utilities, instead of taking the easy road of making off the cuff complaints on rate matters it doesn't understand in order to grandstand for the media? They could actually save ratepayers buckets of money and do something useful for a change. In no instance should the public, or ratepayers, financially reward Public Citizen for this counterproductive, wasteful behavior.

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Transource Applies Some Lipstick To Its Pig

10/18/2019

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I haven't written about the Transource Independence Energy Connection transmission project in quite a while, but now news articles are being cranked out about a possible settlement with Maryland state agencies and some landowner parties (including Harford County, Maryland, which technically isn't an affected landowner, but a stakeholder none-the-less).

A settlement may indicate that all parties have negotiated to come to a reasonable agreement on all issues. A partial settlement indicates that all (or some) parties have negotiated to come to a reasonable agreement on some of the issues presented. The talked-about settlement seems to fall into the latter category. There seems to be one Maryland party missing from the proposed settlement, the Maryland Office of People's Counsel. The OPC represents the interests of electric ratepayers in Maryland as a collective group. The OPC has opposed the project because of its cost to ratepayers compared to its benefit. The OPC has not agreed that the Transource project is a good deal for ratepayers. I agree, it's not. Not at all.

Early this summer, I watched much of the Maryland PSC Transource hearings (thank you, archived video!). It became clear to me (and I'm sure to Transource as well) that the Maryland PSC Commissioners were set to deny the project Transource had applied for. The big stumbling block appeared to be a Maryland law that requires existing assets to be considered before taking new right-of-way for a transmission line. Commissioners appeared to be considering opposition arguments that the project could be successfully constructed using existing transmission lines and rights-of-way. The problem with Transource in Maryland became crystal clear. The project was on the fast track to denial. The only way Transource was going to ever get this project approved was to fall on its sword and change the route to use existing transmission assets as much as possible. It was either that or denial. Take your pick, Transource.

Transource sucked it up and walked back all its baloney about how such a use of existing assets couldn't work. PJM went along for the ride. And the next thing you know, Transource and PJM had worked out the alternative suggested by state agencies and landowners to route the project on existing infrastructure. Next, Transource worked a cloak and dagger settlement process with individual parties that were concerned about routing. Routing was a huge issue, but it wasn't the only issue. Keep that in mind as the future unfolds.

Who could fault targeted landowners from accepting a guarantee that Transource would amend its application to prefer a new route that used existing rights-of-way that did not cross their properties? This is a victory for them, although not a victory for everyone. These landowners worked hard to highlight the fact that there was a better route for the project that spared their properties, and nobody, even Transource, can deny that fact. The landowners got part of what they worked for... a better route! They also set a very important precedent that will affect all PJM transmission projects in Maryland in the future! PJM had been ignoring Maryland's law about using existing infrastructure, paying it bare lip service in transmission applications. That is over for good now. A solid opposition strategy for any future transmission plans emerges from the rubble -- find an alternative that uses existing infrastructure. Because there's always an alternative. PJM has moaned and complained that the routing alternative could cost up to $100M more than the original route, and also reduce the savings for ratepayers by hundreds of millions of dollars. But, in the end, PJM seems to want this project so badly that cost and benefit don't matter all that much. Price and benefit are no obstacle. Will PJM be more mindful to give preference to use of existing assets before approving new greenfield projects in the future? It would be foolish not to, now that opposition has a new tool in their toolbox.

But routing wasn't the only concern of affected landowners on the eastern segment. They also objected to the economic reasoning for the project, doing much work to expose PJM's self-serving analysis and magic math supporting the project, and once exposed, these factors cannot evaporate. The routing change, being more expensive and less economically effective, hurts rather than helps PJM's continued support of this project. The routing change also does nothing for the OPC's position. The OPC doesn't represent landowner interests, it represents ratepayer issues, and those issues have only been magnified by the proposed settlement.

Another factor here is that no landowner parties from the western segment opposed the project at the Maryland PSC. Transource's route through western Maryland was very short, and snaked artfully through properties owned by individuals who would or could not oppose the project due to religious reasons. Transource thinks it has landowner opposition in Maryland tackled. The OPC is the one remaining wild card. What does Transource have to offer OPC in settlement? Even more costs for ratepayers with less benefit? The settlement isn't a good deal for Maryland ratepayers. If and how OPC will oppose the settlement remains to be seen.

The settlement isn't a guarantee that the Maryland PSC will approve it. It's just Transource's last hope for success in Maryland.

But wait! Transource must also receive approval from the Pennsylvania PUC before it may build the project. There is landowner opposition on the western segment in Pennsylvania, where the route hasn't changed, and Transource has nothing to offer these people, except a handful of grease to make it a little less painful. Kind of insulting, don't you think?

Transource must also update its preferred route in Pennsylvania, and bluster its way through the claims about reliability it lamely tried to raise as a shield against denial before seizing on the routing change necessitated by Maryland's law. And here's the huge brick wall staring them in the face... the Transource project will cause hundreds of millions of dollars of increased electric costs for Pennsylvania ratepayers while providing them no benefit at all. Routing is much less of an issue in Pennsylvania, where the PUC may only be put in the precarious position of choosing whether to toss one group of landowners under the bus in order to favor another group of landowners who are satisfied with a changed route. Routing is a sideshow in Pennsylvania, mere lipstick on a pig. Pennsylvania also has a powerful and dedicated consumer advocate representing its state's ratepayers, and those ratepayers aren't getting any benefit from the proposed settlement. In fact, they're not even getting a handful of grease. They're getting nothing at all.

Increased costs and decreased economic benefit is going to do a number on PJM's cost/benefit ratio. PJM's magic math was called into question in the original application and evidence was introduced showing it was unrealistic. A second look may reveal even more magic math as PJM struggles to absorb the additional costs of the re-routed project and decreased economic benefit. PJM's math is going to go under the microscope. How does a project using existing rights-of-way (no new land costs, no major environmental studies, no siting issues) and even existing transmission structures (fewer new towers) end up costing more? And how much money has Transource wasted, just completely wasted, on trying to route and engineer its original route? Remember, Transource has spent the past several years harassing landowners along the original routes with surveys, turtle hunts, right-of-entry lawsuits, and easement options. It wouldn't surprise me to find that Transource's pursuit of its original route has wasted more than $100M. Why was this money wasted? Because PJM and Transource imprudently failed to follow Maryland law and thought they could bully their way through approvals. Ratepayers paying for the Transource project will pay all of Transource's costs for its botched original route, in addition to re-routing and re-application. How could this project still possibly be economically beneficial? How far down the tunnel are PJM and Transource, and will they ever come out to take a breath and acknowledge what a colossal waste of time and money this project has become?

There is no benefit from the Transource project. It should be rejected by both state utility commissions because its entire premise of market efficiency has become a costly joke. Pretending it's not because Transource fell on its sword regarding a routing issue is nothing more than lipstick on a gigantic, gluttonous pig.

Congratulations to the eastern segment landowners who successfully saved their farms and taught PJM a valuable lesson that will benefit everyone in the future! And renewed support and encouragement to the western segment landowners who will continue to fight for their own interests (and mine as a ratepayer on the hook for this porcine boondoggle)!

It isn't over until it's over. Just remember, canceling this project outright benefits EVERYONE. Fight on!

Addendum: While I was writing this, the proposed settlement was publicly filed at the MD PSC. You can read it here.

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Forward>>

The REAL End For The PATH Project Finally Arrives

Transource Continues To Waste My Money As Hearings Continue

"Wolf!", Cried Sierra Club

Maryland Office of People's Counsel Digs Into PJM's Magic Math

More Trouble In Transourceland

PJM Market Monitor Recommends Market Efficiency Process Be Eliminated

Transource IEC No Longer Meets PJM Benefit Cost Ratio

Was PJM Lying Then, Or Is PJM Lying Now?

Public Citizen Slapped Down by FERC After Filing Another Frivolous Complaint

Transource Applies Some Lipstick To Its Pig

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