PJM Interconnection why do you filter the comments on your page, why do you not allow the public to share comments or post concerns??? Don't appreciate it when the public calls you out on your lies??? After our community hearing with the Maryland Public Service Commission I am back into full fledged pissed off mama bear mode, and I have ZERO plans of backing down. The entire project is unfounded, unjust, unnecessary and provides no benefit to anyone but YOU and your own financial gain. It will be a cold day in hell before I willingly allow you to destroy my community, our homes, property or my childrens back yard.
*EDITED*, I never expected all the shares, so I wanted to write a bit more of an explanation for those who aren't aware of that's going on.
PLEASE SHARE AND TAG TO SPREAD MORE AWARENESS!!!!!
I'm reaching out to everyone single person I can and through every single avenue there is. Crazy long story short for those who have no idea what's going on. A huge multi million dollar electric company PJM Interconnection has plans to build a new high tension powerline in northern Harford county MD, Washington county MD and Franklin county PA. This is a powerline that serves no purpose, and does nothing to benefit the general public, only the big power companies will reap the benefits. To make matters worse, there are existing underutilized towers that could solve the problem, without having to build a new transmission line. Currently they have plans to enforce eminent domain (steal our land) to build this line, and plan to disrupt homes, farms, orchards and small businesses. They have intentionally chosen farms in agricultural preserve because the land is "cheaper", and hold "less value", so therefore more cost efficient for them to steal. Unfortunately if the state allows this to happen, it will set a precedent that huge money hungry corporations can steal land from whomever they chose for their own financial gain. Does this directly impact you now ?? Maybe not, but I certainly never thought I'd be facing this issue, but here I am. Please Help spread the word. Share share share and share again!! They currently plan to go directly through my husbands great grandparents farm that we were blessed to have been able to build our dream home on, the land that we thought would allow our 3 small sons to safely grow, learn, play and explore. This project, if approved is going to ruin those hopes and dreams. So please, help make this issue known, and spread the word.

Welcome to our Mason-Dixon Community. A Community at risk due to a broken PJM process.

PJM holds the view, that agricultural land is “undeveloped land” ready and waiting for their transmission projects. PJM fails to consider or care about the negative impacts their transmission projects have on our local economy, local agricultural businesses, rural pastoral viewsheds or the rural Community in general. PJM fails to recognize that agriculture is an intended land use designation. Harford County retains approximately 75,000 acres, or 27%, of the County’s land area dedicated to farming. Agricultural land is in decline and both MD & PA have made preserving agricultural land a priority. We can’t make more farmland.

On November 6, 2017 members of this Mason-Dixon Community, along with elected and appointed officials from both MD & PA met with PJM staff, Paul McGlynn (PJM System Planning), Matthew LaRocque (Manager Regulatory Affairs for MD, VA & NC), and Darlene Phillips (PJM State and Member Services) as a result of a written request to PJM’s Board Chairman. The purpose of this meeting was to resolve the need for any new “greenfield” transmission projects in our Community.

What was and is still disturbing is the failure of PJM and their staff to acknowledge that, as citizens, we know what is best for our Mason-Dixon Community. On November 6, 2017, those PJM staff chose to ignore the invitation by Councilman Chad Shrodes to take a five-minute drive to see the underutilized transmission line, the Otter Creek-Conastone line near Shaw’s Orchard in Norrisville. In fact, the Otter Creek-Conastone line parallels and is located within sight of the proposed Transource IEC-East line almost the entire proposed pathway. To validate this one only has to take a drive.

In addition, we were told that “some states have requirements” to utilize existing brownfields vs. building new greenfield transmission. And that “we are all working with the states to work within and respect the state’s regulations”. And that (the project) “was submitted based on state policy”. If those statements were true, PJM wouldn’t have approved Transource to build an unnecessary, redundant IEC-East transmission line in a Community already beset with existing underutilized transmission lines. Something that is very clear to the members of our Community. All one has to do is take a drive.

We expressed concern to PJM staff that the Benefit/Cost analysis only included costs of siting, costs of ROW’s, substation and equipment costs – transaction and infrastructure costs only, costs specific to building the project. A member of the York County Planning Commission told PJM staff, “those are transaction and infrastructure costs only, project costs specifically related to building the project. You are not looking at the farm economy for local farms. Where is the B/C for the Community? We need to come up with this impact.” There was just silence from the PJM staff present. Matter of fact, our Community still has yet to receive an answer from PJM. So, PJM what is the negative impact to our Community? Are you ever going to answer?

Our Mason-Dixon Community urges the Commission to provide that answer to PJM. Tell PJM that their project, the Transource IEC Project is denied. Tell PJM that existing underutilized transmission infrastructure is the best solution for “Market Efficiency” and/or “emerging reliability issues”. Tell PJM that the next time they propose a problem and search for solutions that they need to just take a drive.

The recommendation by the reviewing State Agencies to deny a transmission project is a
rarity and is not made lightly, or without significant analysis and consideration. Yet, this project contradicts Maryland’s well-established statutory planning and preservation priorities. While, the work of PJM is vital to assure the reliability of the electricity grid that serves Maryland, what is most beneficial for the applicant, or PJM and its stakeholders, is not always what is in the public interest of the State and its residents. This discretionary PJM-driven market efficiency project, and the process used to approve it, demonstrates this divergence. As described by the Direct Testimony of the Secretary of Agriculture, Joseph Bartenfelder, and the Executive Director of MALPF, Michelle Cable, Maryland’s agriculture industry is vital to Maryland as its single largest industry after the federal government, which is why Maryland has prioritized preserving farmland and ensuring the integrity of MALPF easements. Projects that diminish the State’s efforts and devalue its investments to preserve this finite resource should not be approved when existing infrastructure is available. PJM and transmission developers should reasonably be expected to incorporate Maryland’s stated policies and statutes into their project development and approval processes.

The MMU recommends the creation of 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.

So how can PJM propose a project that doesn’t really save any money, hurts Pennsylvania ratepayers so badly, and costs nearly $500 million to build? 
 
The answer can be found at the Federal Energy Regulatory Commission (“FERC”), the entity charged with regulating PJM.  FERC allowed PJM to implement a tiered system, with one set of rules for smaller projects, and one for larger projects.  Delineated by voltage, the lower tier rules allow PJM to completely ignore all zones that see increases, while the higher tier rules consider the net change to system production cost.  Transource realized that this created a loophole.  They designed the IEC to run at the highest voltage possible in the lower tier, but carry an astonishing 24 conductors.  Though run at only 230kv, the IEC has so many conductors it would have more power capacity than most 500kv lines that form the backbone of the grid.  One expert witness said it carried more power than any 230kV line he had ever seen.  Testimony showed that if the line were evaluated as a higher tier project, it probably would never have been proposed.

And if that isn’t gaming the system, then consider this: when PJM asked FERC to make the changes in the assumptions for future planned generation – the changes that affected the benefits last week – they didn’t provide much analysis.  In fact, they only gave FERC one table of examples.  Those examples showed what would happen to eight small projects with and without the proposed changes.  In all eight examples, the new rules reduced and usually eliminated the need for those projects by showing the projects no benefit.  PJM clearly was trying to tell FERC that they had historically been over-estimating the benefits of projects, and that the proposed rules would more accurately reflect lower benefits and result in fewer unnecessary projects.  But just days after the rules were changed, the IEC showed a $250M swing the other direction.  Bait and switch anyone?  You can almost hear the laughter in the PJM hallways.

PJM is a cabal of utilities interested in one objective: making money.  They have manipulated the rules to allow the proposal of a project that will lose hundreds of millions of dollars, destroy preserved farmland, and raise rates for Pennsylvania residents, all while ignoring existing alternatives.  If nothing else, this process has convinced any objective onlooker that PJM needs tighter regulation.  FERC has been too trusting, and the effects are clear.

The new figures raise the projected electrical rate increase in Pennsylvania rates from $350M to over $500M (NPV over 15 years).

The new simulation projects $982M in electrical cost reductions for the DC market, but $969M in increases elsewhere, including over $514M in electric rate cost increases in Pennsylvania alone.

If all benefits and costs were to be included, the total benefit of the project would be negative $439M NPV over the next 15 years. 

Citizens to Stop Transource VP Barron Shaw stated: “Transource doubled-down on their bet that Pennsylvania would approve a project that effectively drains low-priced electricity from Pennsylvania in order to subsidize the wealthiest counties in the nation.  This project was bad before, and it is even worse now.  The PUC would be nuts to approve this project.”

I agree with Mr. Herling that if a project can be devised to cost-effectively eliminate the transmission constraint, the entire cost of that project should be borne by customers in Town B. As a matter of cost allocation, that is the fairest way to allocate the cost.

Where PJM and Transource are incorrect, however, is in ignoring the increase in costs in unconstrained areas when determining the benefits of a project. By using only the decrease in costs on the constrained side of the congestion point to determine the benefits of a project, PJM and Transource greatly inflate the benefits of the project, making an uneconomical project look economical.

The most recent information provided by Transource shows that using PJM’s incorrect assessment of benefits (that is, looking solely at zones that would have reduced power costs) results in reduced congestion costs with a net present value of $707.29 million over 15 years. Moreover, as I explained in my direct testimony and as that same schedule shows, the total benefit to PJM (the sum of zones with reduced power costs and those with increased power costs) is only $17.05 million over 15 years.

 In other words, a project with a 15-year cost of almost $500 million would produce just $260 million of system-wide production cost savings over that same time period. This is a further indication that the Project is not economical and should not be constructed.

Under PJM’s methodology for higher-voltage market-efficiency projects, system level production cost savings would receive a 50% weighting in determining the project’s benefits. The other 50% would be made up of savings in the benefiting zones. If that methodology were used for this project, it would result in the Project’s 15-year discounted “benefits” being calculated to be: (50% x $260.13 million) + (50% x $707.29 million) = $483.71 million. This is less than the Project’s 15-year discounted cost of $498 million, meaning that the Project would fail to provide a benefit-cost ratio of 1.0, let alone PJM’s required ratio of 1.25 or higher. Thus, if system-level production cost savings were considered, as Mr. Horger posits, PJM’s own methodology would result in the project failing the benefit-cost test.

Mr. Weber appears to state that my testimony recommends that the Eastern portion of the Project should be replaced either i) by new lines in existing transmission ROWs or ii) by additional circuits on lines already owned by PPL. The first part of this contention is completely incorrect. My direct testimony addresses the use of additional circuits on lines already owned by PPL. It does not address the installation of new transmission lines on new towers along existing ROW. My direct testimony points out that PJM did not evaluate the use of additional circuit positions already available on transmission towers owned by PPL. I do not develop an alternative to the facilities in the eastern portion of Project 9A. I only present the recommendation that use of additional circuits on transmission towers already owned by PPL be evaluated as part of an alternative to the proposed facilities in the eastern portion of Project 9A.